Performance audit, Arizona School for the Deaf and the Blind

PERFORMANCE AUDIT
ARIZONA SCHOOL FOR
THE DEAF AND THE BLIND
Report to the Arizona Legislature
By the Auditor General
October 1992
92- 4
DOUGLAS R. NORTON, CPA
AUDITOR GENERAL
STATE OF ARIZONA
OFFICE OF THE
AUDITOR GENERAL
October 13, 1992
Members of the Arizona Legislature
The Honorabie F i f e Symington, Governor
Ms. Betty Borland, Chairman
Board of Directors
Arizona School for the Deaf and the Blind
Transmitted herewith is a report of the Auditor General, A Performance
Audit of the Arizona School for the Deaf and the Blind. This report is
ir response to a December 13, 1991, resolution of the J o i n t Legislative
b* arsight Comittee.
The report addresses the need to 1) streamline the school's management
and administrative hierarchy; 2) strengthen controls over local funds and
donations; 3) improve the Board's oversight of school operations; and 4)
expand the school's role as a statewide resource to local school
d i s t r i c t s . The report also recognizes the s i g n i f i c a n t improvements made
by the school to address concerns raised in our 1987 audit.
My s t a f f and I w i l l be pleased to discuss or c l a r i f y items in the report.
This report w i l l be released to the public on October 14, 1992.
Sincerely,
~ d&& R. Norton
Auditor General
DRN : l mn
2700 NORTH CENTRAL AVENUE . SUITE 700 PHOENIX, ARIZONA 85004 ( 602) 255- 4385 . FAX ( 602) 255- 1251
SUMMARY
The Office of the Auditor General has conducted a performance audit and
Sunset Review of the Arizona School for the Deaf and the Blind, pursuant
to a December 13, 1991, resolution of the Joint Legislative Oversight
Committee. This performance audit was conducted as part of the Sunset
Review set forth in Arizona Revised Statutes ( A. R. S.) 6041- 2951 through
41- 2957. This is the second performance audit of the Arizona School for
the Deaf and the Blind conducted by the Auditor General. The f i r s t
performance audit, Auditor General Report 87- 10, was conducted in 1987.
The Arizona School for the Deaf and the Blind ( ASDB) provides
educat i ona l and other services to sensory- impai red students. The
School's Tucson and Phoenix campuses provide kindergarten through high
school classes for approximately 500 day and residential students. ASDB
also provides preschool and outreach programs for approximately 450
infant and preschool- age children; administers a regional cooperative
program in the northern part of the State to provide improved
educational programming to sensory- impaired students in their home
schools; and serves as a resource to local school d i s t r i c t s . ASDB i s
governed by a seven- member Board that appoints a Superintendent to
oversee school operations.
The School's Administrative Structure Is Top- Heavy And
Could Be Downsized To Save Over $ 500,000 Annually
( see pages 7 through 17)
We found the number of top administrators in ASDB's administrative
structure has grown s i g n i f i c a n t l y since the early 1970s, even though
enrollment at the Tucson campus has declined. Board members,
administrators, teachers, s t a f f , and parents a l l expressed concerns to us
about the School's top- heavy administrative structure. Our analysis of
the administrative structure revealed that 10 positions at the Tucson
campus and one at the Phoenix campus could be eliminated, providing f i r s t
year savings of over $ 400,000 and long- term cost savings of over $ 500,000
annually. These savings could be applied to needed ASDB programs that
have been underfunded.
The Board Should Improve Its Oversiqht And Control
Over Nonappropriated Funds ( see pages 19 through 27)
The Board has allowed school administrators too much latitude in the use
of nonapp rop r i a t ed funds. These funds , wh i ch i nc l ude dona t i ons and l oca l
funds, have in some cases been misused or imprudently used. For example,
the School spent $ 54,070 in trust and other nonappropriated funds for
out- of- state travel in fiscal year 1990- 91, much of i t for
administrators. In two instances, 11 administrators attended the same
conference. In addition, the former Superintendent violated State
purchasing statutes and may have violated c o n f l i c t o f interest statutes
in previous years when he used School funds to purchase $ 3,500 worth of
commemo rat i ve mugs. In another instance in 1989, the former
Superintendent used an estate's $ 2,000 bequest to the School for
out- of- state travel rather than depositing i t in the trust fund for
investment. Board control over nonappropriated funds i s very important
because these monies are exempt from the State budgeting process.
ASDB Has lm~ roved Student
Evaluation And Placement
( see pages 29 through 36)
Our 1987 audit reported major problems with student admission and
placement. Our current review found ASDB has corrected most of these
problems; however, some problems remain with placement of multiply
handicapped students and students with severe emotional disorders.
Programs for these students are costly, and ASDB's role in serving these
students i s unclear. The Legislature should establish a task force of
ASDB, Department of Education, local school d i s t r i c t , and Department of
Health Services o f f i c i a l s to address the needs of these students.
The Board Needs To lm~ rove Its Gc. - - 7ance
Of The Arizona School or The Dea _ , nd The Blind
( see pages 37 through 43)
Board oversight and control of School operations has been weak. Until
informed by several outside parties, the Board was unaware of significant
management and f i nanc i a l prob l ems at the Schoo l . Other ev i dence of the
Board's weak oversight includes i t s fai lure to evaluate the former
Superintendent's performance during four of the last f i v e years; develop
a comprehensive set of p o l i c i e s t o guide administrators in managing
operations and finances; and address substantive policy issues i n Board
meet ings.
Other Issues
In addition, our report contains two findings that address the following
I ssues .
ASDB needs to do more to f u l f i l l i t s mandated role as a statewide
resource to local school d i s t r i c t s . During our review, we found the
regional cooperative program to be successful, and recommend
expanding the program to two other regions. ASDB also needs to
expand other services to d i s t r i c t s , such as evaluation services,
summer programming, and providing equipment and materials. Funds
for expanded programming could be derived from the cost savings
realized by streamlining the School's top- heavy administrative
structure. ( See Finding V, pages 43 through 49.)
ASDB needs to increase i t s e f f o r t s in monitoring the success of i t s
graduates. Tracking graduate performance in the workplace or in
higher education can assist ASDB in determining whether the School's
programming is meeting i t s statutory mandate of preparing students
to lead "... an adult l i f e of independence and self- sufficiency, a
meaningful personal, family and community l i f e , and a useful
productive occupational l i f e . " ( See pages 51 through 56.)
TABLE OF CONTENTS
INTRODUCTION AM) BACKGROUND. . . . . . . . . . . . . . . . .
FINDING I: THE SCHOOL'S ADMINISTRATIVE STRUCTURE
IS TOP- HEAVY AND COUU) BE DOWNSIZED
TO SAVE OVER $ 500,000 ANNUALLY . . . . . . . . . . . . .
Administrative Structure Is Top- Heavy. . . . . . . . . .
ASDB Could Reduce The Number Of Administrative Positions . . . . . . . . . . .
Monies Spent On Administration
Could Be Better Used For Other Purposes. . . . . . . . .
Board Needs To Study
Organizational Issues. . . . . . . . . . . . . . . . . .
Recommendations. . . . . . . . . . . . . . . . . . . .
FINDING II: THE BOARD SHWLD IMPROVE ITS
OVERSIGHT AND CONTROL OVER
NONAPPROPRIATEDFUNDS. . . . . . . . . . . . . . . . . .
Board Has Not Exercised Adequate
Control Over Nonappropriated Funds . . . . . . . . . . .
Poor Judgment Exercised
By Former Administrators . . . . . . . . . . . . . . . .
Board Needs To Strengthen Controls
Over Nonappropriated Funds . . . . . . . . . . . . . . .
Recommendations. . . . . . . . . . . . . . . . . . . . .
FINDING I l l : ASDB HAS IMPROVED
STUDENT EVALUATION AND PLACEMENT . . . . . . . . . . . .
ASDB's Evaluation And Placement
Process Has Markedly Improved. . . . . . . . . . . . . .
Placement Of M u l t i p l y Handicapped Students
Continues To Generate Controversy. . . . . . . . . . . .
Recommendations. . . . . . . . . . . . . . . . . . . . .
TABLE OF CONTENTS ( Con ' t )
INDING IV: THE BOARD NEEDS TO INPROVE
ITS GOVEFWANCE OF THE ARl ZONA SCHOOL
FOR M E DEAF AH) THE BLIND . . . . . . . . . . . . . . .
Board Oversight And Control I s Weak. . . . . . . . . . .
Action To Improve Governance I s Needed . . . . . . . . .
Recommendations. . . . . . . . . . . . . . . . . . . . .
FINDING V: ASDB'S ROLE AS A STATEWIDE RESOURCE
IS NOW CLEARLY ESTABLISHED IN STATUTE;
HOWEVER, UORE NEEDS TO BE DONE TO
FULFILL THIS MANDATE . . . . . . . . . . . . . . . . . .
ASDB I s Now Required To Serve As A
Resource To Local School D i s t r i c t s . . . . . . . . . . .
P i l o t Regional Cooperative Program Has Been
Successful And Should Be Expanded. . . . . . . . . . . .
Services Provided To Local School D i s t r i c t s
Are Limited And Should Be Increased. . . . . . . . . . .
Recommendation . . . . . . . . . . . . . . . . . . . . .
FINDING VI: ASDB NEEDS TO COLLECT W E
COMPREHENSIVE INFOWITION ABWT ITS
STUDENTS' POST GRADUATION SUCCESS. . . . . . . . . . .
lnformation About Student Outcome Is
An Important Management Tool . . . . . . . . . . . . . .
lnformation On Student
Outcome I s Limited . . . . . . . . . . . . . . . . . . .
ASDB Needs To Expand
Follow- Up Of Graduates . . . . . . . . . . . . . . . . .
Recommendations. . . . . . . . . . . . . . . . . . . . .
OTHERPERTINENT INFORMATION. . . . . . . . . . . . . . . . .
SUNSET FACTORS. . . . . . . . . . . . . . . . . . . . . . . .
AGENCY RESPONSE
LlST OF TABLES
Page
TABLE 1 ARIZONA SCHOOL FOR THE DEAF AND THE BLIND
STATEMENTS OF FTEs AND ACTUAL AND
APPROVED EXPENDITURES
FISCAL YEARS 1989- 90, 1990- 91,
AND 1991- 92 ( Unaudited) . . . . . . . . . . . 3
TABLE 2 ARIZONA SCHOOL H) R M E DEAF AND THE BLIND
TRUST FIJM) AND LOCAL FUND
FTORRA VFEILS CEAXPL EYNEDAIRT UR19E9S0 B- 9Y1 PO( USnIaTuIOdiNtSe d). . . . . .
TABLE 3 ESTIMATED COST OF CONSTRUCTION AND
LEASE/ PURCHASE PAYMENTS ON SIX NEW
AND TWO USED UOWLAR BUl LDl NGS AT
ASDB'S TUCSON CAMPUS ( Unaudited) . . . . . . . 59
LlST OF CHARTS
CHART 1 ARIZONA SCHOOL FOR THE DEAF AND THE BLIND
. ADMINISTRATIVE STRUCTURE IN 1974 . . . . . . . 8
CHART 2 ARIZONA SCHOOL FOR THE DEAF AND THE BLIND
ADMINISTRATIVE STRUCTURE
IN FlSCALYEAR1991- 92. . . . . . . . . . . . . 9
CHART 3 ARIZONA SCHOOL FOR THE DEAF AND THE BLIND
PROPOSED ADMINISTRATIVE STRUCTURE. . . . . . . . 14
INTRODUCTION AND BACKGROUND
The Off ice of the Auditor General has conducted a performance audit and
Sunset Review of the Arizona School for the Deaf and the Blind, pursuant
to a December 13, 1991, resolution of the J o i n t L e g i s l a t i v e Oversight
Committee. This performance audit was conducted as part of the Sunset
Review set f o r t h in Arizona Revised Statutes ( A. R. S.) $ 941- 2951 through
41- 2957. This i s the second performance audit of the Arizona School for
the Deaf and the Blind conducted by the Auditor General, The f i r s t
performance audit, Auditor General Report 87- 10, was conducted i n 1987.
School's Purpose, Proarams, And Structure
The o r i g i n a l intent i n establishing the Arizona School for the Deaf and
the Blind ( ASDB) was to provide educational opportunities f o r
sensory- impaired students ages 6 through 21. In 1988, the Legislature
redefined ASDB's mission as follows:
The purpose of the Arizona state school for the deaf and the
b l i n d i s to promote and maintain an educational opportunity of
adequate scope and q u a l i t y for sensory impaired children i n t h i s
state which w i l l lead to an adult l i f e of independence and s e l f
s u f f i c i e n c y , a meaningful personal, family and community l i f e ,
and a useful productive occupational l i f e .
In i t s role, ASDB provides d i r e c t educational services to students and
also acts as a resource to local school d i s t r i c t s . ASDB provides d i r e c t
educational services at campuses in Phoenix and Tucson. The Phoenix Day
School for the Deaf ( PDSD) has an enrollment of approximately 200
students and provides kindergarten through twelfth- grade classes for
hearing- impaired and sensory- impaired, m u l t i p l y handicapped students that
I ive at home i n the Phoenix met ropol i tan area. The Tucson campus has an
enrollment of approximately 150 day and 160 residential students and
provides kindergarten through twelfth- grade classes for students t h a t are
hearing- impaired, visually- impaired, or m u l t i p l y handicapped with a
sensory impairment. Residential students are those that l i v e on campus
during the school year, primarily because t h e i r home school d i s t r i c t
cannot prov i de the needed educat i ona l serv i ces . The Tucson campus a l so
provides evaluation and educational services to m u l t i p l y handicapped
chi ldren with a sensory impairment through i t s Arizona Diagnostic Testing
and Educat i on Center ( ADTEC) .
ASDB also provides other services throughout the State and to local
school d i s t r i c t s . ASDB administers preschool and outreach programs for
approximately 450 infant and preschool- age children. In addition, ASDB
administers a regional cooperative program i n the northern part of the
State i n which 31 school d i s t r i c t s pool special education resources to
provide improved educational programming to sensory- impaired students i n
thei r home schools. ASDB also serves as a resource to local school
d i s t r i c t s for evaluations, c u r r i c u l a , and t r a i n i n g .
ASDB i s governed by a seven- member Board comprising the State
Superintendent for Education or his or her designee and s i x members
appointed by the Governor. The Board appoints a Superintendent to
oversee the d a i l y operations of the School.
Budaet And Personnel
ASDB's operat i ng budget cons i sts of both appropr i ated and nonappropr i ated
funds. Appropriated funds include General Fund monies, a per student
a1 location from the Department of Education's Special Education
I n s t i t u t i o n a l Voucher Fund, and charges for nonresident t u i t i o n .
Nonappropriated funds include Federal grants ($ 508,000 estimated for
f i s c a l year 1991- 921, the school's trust fund earnings, donations, and
local funds. The ASDB's trust fund consists of monies bequeathed to the
school by p r i v a t e donors, which are then invested and managed by a
contracted financial advisor. The current value of the t r u s t fund is
$ 1.6 m i l l i o n , yielding an estimated $ 92,400 in earnings for f i s c a l year
1991- 92. Local fund monies include a1 I other monies a v a i l a b l e t o the
school and are used for a v a r i e t y o f purposes. Finding 1 1 , page 19
describes ASDB's nonappropriated funds.
The Legislature authorized 477.7 f u l l - t i m e equivalent employees ( FTEs)
for ASDB for f i sca I year 1991- 92; however, ASDB employs approximately 800
people to implement i t s program r e s p o n s i b i l i t i e s . Many of these
employees are part- time. Table I, page 3 l i s t s ASDB's expenditures and
the number of FTEs for i t s appropriated funds.
2
TABLE 1
ARIZONA SCHOOL FOR THE DEAF AND THE BLIND
STATEMENTS OF FTEs AND ACTUAL AND APPROVED EXPENDITURES
FISCAL YEARS 1990- 91, 1991- 92, AND 1992- 93
( unaudited)
FTEs
Personal services
Employee related
Prof. & outside services
Travel, in- state
out- of- state( a)
Other operating
Food
Land, Buildings
and Equipment
Lump Sum reduction
TOTAL
1990- 91
Actual
1991- 92
Actual
1992- 93
ADD roved
( a ) ASDB budgets most o f i t s out- of- state t r a v e l from nonappropriated t r u s t and l o c a l fund
monies. For f i s c a l year 1990- 91, ASDB expended $ 54,070 from these funds f o r
out- of- state travel.
Source: Arizona Financial Information System reports for Fiscal Years
1990- 91, and 1991- 92; State of Arizona Appropriations Report for
Fiscal Year ending June 30, 1993.
Audit Methodolow And Scope
In addition to u t i l i z i n g standard audit methodology, such as data
analysis, records review, and interviewing, we employed other methods to
determine the efficiency and effectiveness of the School's operations and
programs. We surveyed a l l 233 local school d i s t r i c t s i n the State. We
also surveyed a stat i s t i c a l ly s i g n i f i c a n t sample of parents of chi ldren
in ASDB programs and parents of children in the regional cooperative
program. We also contracted with experts in the f i e l d of education for
the sensory- impaired to evaluate and determine whether ASDB had resolved
the problems concerning student evaluation and placement we found in our
previous audit.
Our audit report of ASDB presents findings and recommendations in six
areas :
Whether ASDB1s management structure is top- heavy and could be
downs i zed
Whether ASDB1s nonappropr i ated funds have proper oversight and
control
Improvements and continued problems with student evaluation and
p l acemen t
Adequacy of Board governance of school operations
Need for ASDB to expand i t s role as a resource to local school
d i s t r i c t s
Need for ASDB to track student postgraduate performance
In addition to these audit areas, we present a section of other pertinent
information that includes information on the adequacy of teaching methods
and equipment at the School and an overview of the scope and progress of
the School's building program ( see pages 57 through 60). In addition,
this report contains a response to the 12 Sunset Review factors ( see
pages 61 through 65).
The audit was conducted in accordance with government auditing standards.
The Auditor General and staff express appreciation to the President of
the Board of Directors, Board members, and the management and staff of
the Arizona School for the Deaf and the Blind for their cooperation and
assistance throughout the audit.
FINDING I
THE SCHOOL'S ADMINISTRATIVE STRUCTURE IS TOP- HEAVY
AND COULD BE DOWNSIZED TO SAVE
OVER $ 500,000 ANNUALLY
ASDB's administrative structure has an excessive number of top
administrators, and some positions could be eliminated so that monies
could be better spent on direct services to students. In addition, the
Board should study some other organizational and position- related issues.
Administrative Structure
Is T o p H e a w
Despite a decline in enrollment at the Tucson campus, ASDB's
administrative structure has grown significantly since the early 1970s.
Board members, administrators, staff, and parents have expressed concerns
about ASDB's top- heavy administrative structure. As a result of these
concerns, we examined the administrative structure to determine whether
various positions were needed.
Growth of the administrative structure - The number of ASDB
administrators has increased since the early 1970s, particularly at the
Tucson Campus. However, during the same period, the Tucson campus
enrollment has decreased approximately 25 percent, from 418 students in
1974 to 310 in January 1992. In 1974, the administrative structure was
fairly simple and streamlined. Since 1974, the structure has grown in
both numbers of administrators and layers of administration. For
instance, the creation of several director- level positions added a layer
to the management structure and additional directors have been added over
the years.(') Charts 1 and 2 ( pages 8 and 9) illustrate the increase by
comparing ASDB's administrative structure in 1974 with the current
structure.
( 1 ) Two off- campus programs have been added since 1974. The Regional Services Program
serves 450 sensory impaired i n f a n t s and preschool c h i l d r e n throughout t h e S t a t e . The
Regional Cooperative Program p r o v i d e s e d u c a t i o n a l o p p o r t u n i t i e s t o sensory impaired
students i n t h e i r home school d i s t r i c t s . Our a n a l y s i s , however, focused p r i m a r i l y on
the Tucson campus a d m i n i s t r a t i v e s t r u c t u r e .
ARIZONA SCHOOL MR THE DEAF AH) THE f3LlhD
ADMINISTRATIVE STRUCTURE
IN 1974
SUPER1 NTENDENT n
SUPERINTENDENT
1 V1ocAT- xonA1L ~ 1VOC ATIONAL wPTE~ AlC! H" EsRx w
EDUCATION EDUCATION ( a)
- - 7
SUPERVISING
ELEMENTARY
SUPERVI S I f f i
TEACHER
SUPERVISOR
HOUSEKEEPING
( a ) This i s one position which serves both the deaf and blind schools.
SUPERVISOR
BUILDINGS 6
GROUNDS
FOOD SERVICE F\ Fl
BUSINESS
MANAGER
PRI NClPAL PRINCIPAL DIRECTOR DIRECTOR
DEAF SCHOOL BLIND SCHOOL STUDENT PHOENIX DAY
LIVING SCHOOL
+ 1 # ; I
I I I I
SPECIAL
PROGRAMS
DIRECTOR
i -
CHART 2
ARI U) NA SCHOOL FOfl THE DEAF AND THE BL lND
MYINiSTRATiVE STflEWE
IN FISCAL YEAR 1991- 92
ASSOCIATE - I W P E R l Y I E * D E * I
I DUS 1 F I N I ASSOCIATE
SWERlMlE*) EMl
CUI L IYS1R I
DAY YYODL 1YE . LI* D StRVICES 1111 DEAF
I
I Dssy 1 I D I R E C l m YLUGER
C W T f R A I I V E
SERVICES OWUS US W l M l E U K f SERVICES
SERVICE
r 0 5 0 c w s I
H SERVICE SPEC Y Y E R V I YIII
MEDIA L Ml* I
Widespread concern about towheavv administration - Board members,
administrators, s t a f f , and parents have expressed concerns about the
number of top administrators and middle managers at ASDB. The perception
that the administration i s top- heavy i s shared among these groups, as
summarized below.
Four Board members indicated to us that the administration is
top- heavy and one suggested that monies spent on administration could
be used to provide direct services to students. In fact, the Board
has discussed this issue at i t s meetings and plans to study the
organizational structure to address these concerns.
Administrators and s t a f f members view the administration as being
top- heavy. Teachers and residential s t a f f have suggested that the
top administration be reorganized and that administrative secretarial
s t a f f be cut to reduce positions. In addition, several
administrators and s t a f f pointed out particular positions that they
consider unnecessary. Some s t a f f members were also concerned that
during a reduction in force ( RIF) budget cut last year, although
direct service positions were cut, management positions were not
reduced.
Parents also indicated that the number of administrative positions
should be reduced. During deliberations about last year's RIF
parents suggested cutting administrators rather than direct service
functions for students.
ASDB Could Reduce The
Number Of Administrative Positions
The Board should downsize ASDB's administrative structure. We found that
ASDB could eliminate 11(') administrative positions.(') The
organizational structure resulting from these reductions would allow
adequate coverage of the du t i es and func t i ons necessary to manage the
Schoo I .
Administrative positions could be eliminated - During our audit we
i d e n t i f i e d the following 11 positions that could be eliminated from upper
( 1 ) These 11 p o s i t i o n s include two part- time p o s i t i o n s and equate t o a t o t a l of 10 FIE
p o s i t i o n s .
( 2 ) Our examination consisted of reviewing job d e s c r i p t i o n s , determining spans of c o n t r o l ,
comparing ASDB's s t r u c t u r e w i t h other state schools, reviewing previous ASDB proposals
f o r s t a f f reduction, comparing the current s t r u c t u r e w i t h ASDB's past s t r u c t u r e s , and
i n t e r v i e w i n g numerous management and s t a f f members. I n a d d i t i o n , our consultants were
asked to comnent on the organizational s t r u c t u r e . Management p o s i t i o n s were
considered f o r e l i m i n a t i o n i f we determined that the duties and functions of one
administrative p o s i t i o n could be s u f f i c i e n t l y covered by another p o s i t i o n .
and middle management, which would eventually save over $ 500,000
annually(') in salaries and benefits.
The Associate Suoerintendent for Curriculum and I n s t r u c t i o n position
($ 74,000) is unnecessary. The Associate Superintendent i s
responsible for the oversight of the academic programs. However,
this position was vacant from August 1991 to July 1992 while the
Associate Superintendent served as Acting Superintendent. The
Directors operate the programs on a day- to- day basis and could report
d i r e c t l y to the Superintendent. In addition, a study found that few
other states operate schools for the deaf and the blind with an
Associate Superintendent.
The Assistant F a c i l i t i e s Mana~ er position ($ 42,000) on the Tucson
Campus is not a full- time supervisory position; rather, the Assistant
F a c i l i t i e s Manager assumes the responsibility of F a c i l i t i e s Manager
in his absence and performs carpentry work. Currently, the
F a c i l i t i e s Manager is coordinating the building program and i s often
busy with construction- related items. The end of the building
program this December w i l l allow the F a c i l i t i e s Manager to resume the
day- to- day supervision of personnel and routine maintenance matters.
Therefore, the Assistant F a c i l i t i e s Manager position w i l l not be
necessary.
The Hiah School P r i n c i ~ a l in the School for the Deaf position
($ 62,000) is unnecessary and could be eliminated by combining the
middle school and high school programs. The School for the Deaf in
Tucson currently has three Principals to serve 186 students, while
the Phoenix Day School for the Deaf ( PDSD) operates with only two
Principals for 209 students. In addition, the High School Principal
in the School for the Deaf has the smallest span of control of a l l
the Principals in the academic departments, supervising only seven
teachers. By contrast, the PDSD Principals supervise an average of
( 1) A l l p o s i t i o n costs shown i n parentheses were determined u s i n g t h e s a l a r y and b e n e f i t s
of the person c u r r e n t l y holding the p o s i t i o n . Salary amounts have been rounded to the
nearest thousand d o l l a r s . I n c o r p o r a t i on of ASDB's " bumping" p o l i c y would, however,
reduce the immediate d o l l a r savings. The pol i c y provides permanent employees, whose
p o s i t i o n s are eliminated, w i t h c e r t a i n " bumping r i g h t s " t o other ASDB p o s i t i o n s f o r
which they may q u a l i f y . An i n d i v i d u a l who bumps i n t o a lower c l a s s i f i c a t i o n i s placed
a t the step i n that c l a s s i f i c a t i o n closest to t h e i r c u r r e n t s a l a r y . Since the
i n d i v i d u a l s they are bumping have the l e a s t s e n i o r i t y i n the c l a s s i f i c a t i o n , i t i s
common t h a t the i n d i v i d u a l bumping i n t o that c l a s s i f i c a t i o n ( from a higher p o s i t i o n i n
the agency hierarchy) w i l l earn more than the i n d i v i d u a l they are bumping. The
immediate net savings i n the R I F process i s the s a l a r y / b e n e f i t s of the employee
a c t u a l l y bumped from the agency plus or minus any costs/ savings that accrue through
the bumping chain of events. However, given turnover, promotions, e t c . , over time the
f u l l savings from e l i m i n a t i n g a p o s i t i o n are r e a l i z e d .
ASDB estimates the immediate savings to be approximately $ 413,000 annually f o r the
positions i d e n t i f i e d i n t h i s f i n d i n g .
19 teachers plus instructional aides. Our consultants recommend that
the Deaf High School and Middle School be combined to enhance the
program for students in both departments. They stated that two
Principals were not necessary to run the middle school and high
schoo l programs.
We contacted three schools in other states regarding t h e i r programs
and found that the South Carolina School for the Deaf and Blind,
which i s similar in size to ASDB, has only two assistant principals.
Also, the Arkansas School for the Deaf, which is comparable to the
Deaf School i n Tucson, eliminated two of their principals, and the
superintendent indicated that she has not received any complaints
from s t a f f concerning t h i s change.
One Dean position in the School for the Deaf ($ 46,000) could be
eliminated by combining the elementary and advanced residential
programs under the direction of one Dean. The Deans head the
residential programs and supervise the Teaching Parents and Night
Supervisors that instruct and supervise pupils after school. In
1974, two Deans administered three residential programs serving over
246 students. Today, four Deans serve only 160 students and provide
l i t t l e direct supervision because they work day hours while t h e i r
subordinates work evening hours. Any additional s t a f f supervision
that may be necessary could be provided by the Master Teaching
Parents, who are the experienced residential s t a f f . Because the job
descriptions for Master Teaching Parents provide for them to assume
the supervisory responsibility for residential s t a f f , direct support
to residential s t a f f should not suffer.
The Re~ ional Cooperative Proaram Di rector posi t ion ($ 72,000) is
unnecessary. Currently, the one Regional Cooperative is administered
by a Regional Supervisor in Flagstaff and a ful I- time Director based
in Tucson. Two administrators are unnecessary for t h i s program,
because North Central Regional Cooperative is managed by the Regional
Supervisor on a day- to- day basis. Further, even as additional
regions are developed, oversight of the program could be provided by
the Regional Services Program, which already provides services on a
statewide basis.
The ADTEC Director position ($ 75,000) could be eliminated by placing
the evaluation and education functions in other departments since
these evaluation and education functions w i l l be physically separated
upon completion of the new buildings next f a l l . The ADTEC evaluation
functions w i l l share the same f a c i l i t y with the Department of
Instructional Support Service's ( DISS) evaluation functions.
Therefore, the ADTEC and DlSS evaluation functions could be combined
in an agencywide resource in one department. Additionally, the ADTEC
education component could be administered by the Director of the
Blind School. The Principal of ADTEC would report to that Director.
This organization has been successfully implemented at the Florida
School for the Deaf and Blind.
PDSD Assistant Director posit ion ($ 66,000) i s unnecessary and could
be eliminated. The current role of the PDSD Assistant Director i s to
oversee the educational programs while the Director handles the
business operations of the school. However, because direct
supervisory responsibility for the business and finance operations
was sh i f ted to managers on the Tucson Campus i n 1989, two superv i sors
are unnecessary. Therefore, the Director could assume responsibility
for the educational programs, and the Tucson Campus Business and
Finance Supervisors could manage the business operations, which would
eliminate the need for the Assistant Director. This would bring PDSD
in line with other ASDB academic programs by c u t t i n g t o only two
layers of administration, instead of the current three layers: the
Director, Assistant Director, and Principals.
Four Administrative Secretarv ~ o st iio ns(') ($ 70,000) that support
the Associate Superintendent of Curriculum and Instruction ( 1 FTE),
the ADTEC program ( 1.5 FTE), and the Regional Cooperative Program
Director (. 5 FTE) w i l l not be necessary when the administrative
structure is reorganized.
Pro~ osed reoraanization would ~ r o v i d e for adeauate mana~ ement of Am -
As previously noted, the revised organizational structure would provide
s u f f i c i e n t management personnel to e f f e c t i v e l y perform the duties of the
eliminated positions. The structure that would result from eliminating
these 11 positions is shown in Chart 3, page 14. The reorganized
structure would reduce the layers of top administration from four to
three and also reduce the number of Director- level positions from seven
to f i v e .
The Board has expressed the desire to evaluate and possibly propose an
alternative restructuring that would capture similar dollar savings. The
Board has set aside funds to perform a management study. In addition,
the Board noted that the recently hired new superintendent should have
some f l e x i b i l i t y in organizing his administration. The Board's concept
has merit. Our review and recommendations are based on the school's
existing administrative structure. However, any reorganization based on
a different structure should s t i l l be expected to identify comparable or
greater administrative savings.
( 1 ) These f o u r p o s i t i o n s c o n s i s t of three FTEs
ARIZONA SCHOOL H) F1 THE DEAF AH) VHE BLIND
PROPOSED AOUINISTRATIVE STRUCTllRE
1 I I ? ERSO*( NL
DIRECTOR
Ir" ut B L I" I D I I @ SERVICE
f U L R V I W
EVALUAIIQI
SERVICE
L 1 - 1 I* I
B L I I D XnOOk 191EC lEOIOUL COOT
SERVICE Wf C
Monies Spent On Administration
Could Be Better Used For Other Purooses
The monies spent on the administrative salaries could be better used for
direct services to students if the 11 administrative positiotas were
eliminated. For example, part of the $ 500,000 annual savings could be
used to fund expansion of the Regional Cooperative Program.
Reaional Coo~ erative Proaram exDansion would require $ 291,300 - The
monies saved from reducing the administrative structure could be used
to fund two additional regional cooperative programs. Expanding the
program to two additional regions would cost an estimated
$ 291,300('), This expansion would meet the statutory mandate for
three regional cooperatives and would serve children in their home
districts in the least restrictive environment. Although ASDB has
consistently included funding for these regions in their budget
request since fiscal year 1989- 90, these regions have not been
funded. ( See Finding V, page 43 for further discussion of the need
to expand the regional cooperative program.)
In addition to expanding the Regional Cooperative Program, the savings
could be used to help fund other needed programs. Several of the needed
programs are described below.
New educational Droarams and eauiwent - The saving could also be
used to help fund a program to serve severely emotionally disturbed
students ( see Finding I l l , page 29). In addition, specialized
education equipment could be purchased for the use of new as we1 l as
present programs. In recent years, the special education equipment
budget has been cut severely; consequently, there is a great need for
this type of equipment. For example, the entire 1990- 91 budget for
specialized education equipment was eliminated due to mid- year budget
cuts. ( See Other Pertinent Information, page 57.)
Phvsical facilities imorovements - According to ASDB's capital budget
request for fiscal year 1992- 93, the School's physical facilities
need improvements, such as ai r condi t ioning in the gym and one
dormitory, alarm system upgrades, iocker room repairs, handicapped
access to rest rooms, and furnishings for the new high school
building. Also, the fire alarm systems in the gym and four residence
halls are inadequate and in violation of the State fire code.
I,
( 1) Estimate obtained from the 1992- 93 ASDB Operating Budget Request.
Expanded resource services for local school d i s t r i c t s - ASDB is
required by statute to be a resource to local school d i s t r i c t s , and
the savings from reducing the administrative structure could be used
by ASDB to comply with this mandate. According to ASDB o f f i c i a l s ,
few services are currently being provided to local school d i s t r i c t s
due to funding limitations. ( See Finding V, page 43 for further
discussion of the need for expanded resource services.)
EDP supwrt - Based on our review, the EDP function appears to be
understaffed, and more EDP support seems to be needed. Only one FTE
position i s currently allocated for EDP functions, which consists of
two half- time positions, the Grants/ Compliance/ EDP Coordinator and
the Systems Operator/ Videographer. The EDP system does not contain
basic information such as complete enrollment and student records.
In addition, the Manager i d e n t i f i e d many programming and other
projects that are needed to improve the efficiency and effectiveness
of the data processing system.
Board Needs To Study
Oraanizational Issues
The Board needs to study other issues related to the organization of
ASDB, including the evaluation of positions affected by the downsizing,
and the role of PDSD administrators in business and finance operations.
The Board determined that a management study of ASDB is needed and
allocated monies in fiscal year 1991- 92 for the study. However, they
decided to postpone the study u n t i l they receive the results o f t h i s
audit. Based on our review, the Board should conduct further study in
two key areas:
Effects of downsizinq on positions should be studied - The Board's
study should include an evaluation of the s t a f f whose duties or
responsibilities change as a result of restructuring to consider
salary adjustments. For example, the Master Teaching Parent position
would be expanded upon elimination of one Dean, and a salary
adjustment for the new responsibilities could be necessary.
Role and r e s w n s i b i l i t ~ for business functions at PDSD needs to be
c l a r i f i e d - The Board needs to c l a r i f y the role of PDSD and Tucson
Campus administrators in the operation of the Food Service,
Transportation, Accounting, and F a c i l i t i e s functions at PDSD. The
managers of these operat ions are based on the Tucson Campus and are
charged with the responsibility for these functions at both the
Tucson and PDSD Campuses. However, i t seems the Di rector of PDSD is
managing these operations. For example, the control of some
financial matters lies with the Director, and the Tucson Campus
Manager has l i t t l e knowledge of the use of some monies. As a result,
some problems with the financial transactions at PDSD have been
identified, as discussed in Finding 1 1 , page 19.
RECOMMENDATIONS
1.. The Legislature should consider reallocating appropriations for the
following 11 positions or other administrative positions i d e n t i f i e d
by the Board to the regional cooperative programs and other direct
student service programs:
Associate Superintendent of Curriculum and Instruction
Assistant F a c i l i t i e s Manager
High School Principal in the School for the Deaf
One- Dean in the School for the Deaf
Regional Cooperative Program Director
ADTEC Director
Four Administrative Secretaries
Assistant Director of PDSD
2. The Board should cost out needed programs and establish p r i o r i t i e s
for using the monies saved to provide programs for direct services to
students. The Board should then propose these alternatives to the
Legislature for their consideration.
3. The Board should conduct further studies of the positions affected by
downsizing and the role of PDSD administrators in business and
finance operations.
FINDING II
THE BOARD SHOULD IMPROVE ITS OVERSIGHT AND CONTROL
OVER NONAPPROPRIATED FUNDS
The Board should exercise greater control over the use of non-appropriated
funds. In the past, poor judgment by ASDB administrators
has resulted in State law and p o l i c y v i o l a t i o n s , excessive out- of- state
travel expenditures, and improper use of donations and other monies. To
correct these conditions, the Board should strengthen i t s oversight and
control of nonappropriated funds.
Board Has Not Exercised Adequate
Control Over N o n a ~ ~ r o ~ r i a tFeundd s
The Board has not used i t s authority to properly control nonappropriated
funds. The Board is s t a t u t o r i l y responsible for a l l monies received by
the School, including those that are not appropriated by the
Legislature. ASDB has several sources of nonappropriated funds,
including the trust fund, trust fund earnings, private donations to ASDB,
and local f- und monies.(') Income from these sources, which is described
below, exceeds $ 100,000 per year.
Trust fund and earninas - The trust fund consists of monies and other
assets bequeathed to ASDB. These monies, total ing approximately $ 1.6
m i l l i o n , are managed by the Board through an investment
counselor.( 2) The fund is expected to earn $ 92,400 in 1991- 92. In
1990- 91, trust fund earnings totaled approximately $ 88,600, of which
a l mos t $ 86,700 was expended.
Donations - ASDB receives donations in varying amounts from private
parties throughout the year. The ASDB Tucson Campus received
approximately $ 18,400 in donations and PDSD received approximately
$ 4,600 in fiscal year 1990- 91. Over the last four years, ASDB Tucson
has received an average of over $ 20,000 annual l y i n donat ions.
( 1 ) ASDB a l s o receives Federal g r a n t s . The f i s c a l year 1991- 92 budget i n c l u d e s an
estimated $ 508,000 i n Federal funds. Use o f these Federal monies was n o t reviewed as
p a r t o f t h i s a u d i t .
( 2 ) The investment p o r t f o l i o market value was $ 1,649,423 on March 31, 1992.
Local funds - Local fund monies are raised by ASDB a c t i v i t i e s and
expended for a wide v a r i e t y o f items. For example, a local fund was
established for the receipts of the sale of curriculum materials.
Board lacks control of donations and local fund monies - A1 though the
Board has improved the control over t r u s t funds, the Board allows
administrators too much discretion i n the use of donations and local
funds. The Board does not have knowledge of the donations received or
the ASDB administration's intended use of these funds. When donors do
not specify a purpose for the g i f t , administrators have been free to
deposit the monies i n any local or t r u s t fund earnings account without
informing the Board.
The Superintendent can a l s o e s t a b l i s h local funds and deposit monies i n t o
these funds. In addition, an authorized administrator can expend the
local fund monies without the knowledge or approval of the Board. The
Board generally does not receive any information regarding local funds.
Lack of oversight for nonappropriated funds was also an issue during our
1987 audit. In 1988, the Legislature amended ASDB's l e g i s l a t i o n to
require the Superintendent to report to the Board on the use of these
funds. In response the Board has tightened controls over t r u s t fund
expenditures by requiring that the t r u s t fund be budgeted in greater
d e t a i l , l i m i t i n g transfers between budget categories to less than 10
percent without Board approval, and requiring that a l l out- of- state
travel to be pre- approved by the Board. However, our current audit work
indicates that the Board s t i l l lacks information about donations and
local funds and has not adequately controlled t h e i r use.
Poor Judament Exercised
By Forme Administrators
Former administrators at ASDB have used poor judgment in handling t r u s t
fund earnings, donations, and local fund monies. In two cases,
administrators violated State laws and p o l i c i e s . More commonly, t r u s t
fund earnings and local fund monies have been used by administrators for
excessive out- of- state t r a v e l . In addition, some donations received by
the School have been poorly managed by former administrators, and local
fund monies have lacked oversight.
State laws and policies violated - We i d e n t i f i e d two instances in which
ASDB former administrators violated State laws or policies.
Exam~ le 1 - In the summer of 1986, the then ASDB Superintendent
ordered approximately 3,000 coffee mugs intended to help commemorate
the 75th anniversary of the School. The mugs were purchased at a
price of $ 2.55 each for a total procurement of approximately $ 8,700.
After the order was placed but before i t was delivered, ASDB business
o f f i c e personnel informed the Superintendent that he had violated the
State Procurement Code by f a i l i n g to seek competitive bids for the
procurement of the mugs. In response, the Superintendent contacted
the ASDB Alumni Association ( which consisted primari ly of ASDB
graduates employed at the School) and requested that they purchase
the mugs from the vendor and then s e l l them at a higher price as a
means of raising funds. However, since the Alumni Association only
had approximately $ 2,000, the Superintendent personally borrowed
$ 6,700 from a t h i r d party and loaned i t to the Association to pay the
balance of the amount due. The Association agreed to repay the
Superintendent from the proceeds of the mug sales.
Over the next several months, the Alumni Association sold the mugs
for $ 5 to $ 6 each to various groups, including sources within the
School. In t o t a l , more than $ 3,500 of ASDB funds were expended on
the purchase of mugs from the Alumni Association: $ 1,500 of trust
fund earnings, $ 1,370 of local funds, and $ 648 of general funds.
Over $ 2,000 of these expenditures were speci f ical ly approved by the
Superintendent, and records indicate that the Superintendent received
$ 5,610 back from the Alumni Association.
Comnents - Several statutory violations occurred as a result of the
mug purchase and sales. F i r s t , while acting on behalf of the School,
the former Superintendent clearly violated the procurement code when
placing the order for the mugs without obtaining competitive bids.
Second, purchases of the mugs by school o f f i c i a l s from the Alumni
Association were also v i o l a t i o n s o f the State Procurement Code,
because competitive bids were not obtained and public funds were
used. Third, in an e f f o r t to evade the i n i t i a l v i o l a t i o n o f the
Procurement Code, the former Superintendent may have also violated
the State c o n f l i c t of interest statutes when he authorized the
expenditure of ASDB funds to purchase mugs from the Alumni
Association after he loaned money to the Association and therefore
had a substantial interest in the loan being paid.
Exam~ le 2 - On July 26, 1991, PDSD signed a rental agreement with the
Arizona College of the Bible, a private concern, for the use of the
PDSD Sportsdome. The agreement allowed the college to use the gym
for i t s 1991- 92 basketball and volleybal I schedules totaling 47
games. For the rental, PDSD charged the college $ 1,400 which the
college paid PDSD in two instal lrnents of $ 700 in August 1991 and
January 1992. These monies were deposited in the PDSD local fund.
Ccnmtents - The gym at PDSD is fully funded for normal operating costs
for the year in the budget of the general fund. According to the
Department of Administration ( DOA) Finance Department, the proceeds
from the rental of the facility should be accounted for in the
general fund as a miscellaneous revenue. ( In addition, our legal
counsel believes that the monies should be reported by the
Superintendent to the Board and included in the Board's report to the
Legislature.) However, the Director deposited the rental monies in
the private fund for athletics and theatre. The Director should have
been particularly aware that this violated State pol icy, as ASDB had
unsuccessfuIly sought legislation in fiscal year 1990- 91 to obtain
authorization to deposit rental revenue in student activities
accounts .
Out- of- state travel expenditures excessive - ASDB used nonappropriated
monies for an excessive amount of out- of- state travel. In fiscal year
1990- 91, $ 49,257 ( approximately 57 percent) of the trust fund earnings
were expended for out- of- state travel. Another $ 4,813 was expended for
travel from other local funds in that fiscal year. One- half of the
monies ( 52 percent) was spent for travel for administrators. il) See
Table 2, page 23 for a summary of 1990- 91 out- of- state travel. In some
cases, travel costs were excessive. For example,
Eleven administrators attended the Conference of Educational
Administrators Serving the Deaf ( CEASD) Annual Convention in New
Orleans in June 1991, at a cost of $ 8,972.
Seven teen ASDB staff at tended the 1989 CEASD Annual Convent ion at ' the
Princess Resort in San Diego. Eleven administrators and six staff
attended. Teachers were limited to $ 200 each for the trip. However,
ASDB ful iy funded the cost of the trip for the administrators, at a
cost of up to $ 870 per administrator. The total cost of the trip was
approximately $ 9,800, almost one- thi rd of the total travel
expenditures for the year. The Board approved this trip after the
expenditures were made.
i 1 ) Despite excessive o u t - o f - s t a t e t r a v e l e x p e n d i t u r e s , few t r a v e l funds are a v a i l a b l e f o r
teaching s t a f f . I n f i s c a l year 1990- 91, teaching s t a f f t r a v e l expenditures accounted
f o r only _ percent o f t o t a l t r a v e l expenditures, as shown i n Table 2, page 23. Board
pol i c y h e a v i l y r e s t r i c t s teaching s t a f f t r a v e l , as reimbursement f o r out- of- state
t r a v e l i s l i m i t e d t o $ 200 per t r i p w i t h the remainder o f the costs p a i d by the
teachers. However, the s e c r e t a r i a l s t a f f have been f u l l y reimbursed f o r o u t - o f - s t a t e
t r a v e l . For example, an a d m i n i s t r a t i v e s e c r e t a r y and a r e c e p t i o n i s t t r a v e l e d t o
Denver i n 1990 t o a t t e n d a conference a t a cost o f $ 1,904, which was f u l l y
reimbursed. I n c o n t r a s t , a teacher p a i d a l l the c o s t s o v e r $ 200 from her own pocket
t o a t t e n d a conference i n Washington D . C . , although the ASDB p r i n c i p a l a t t e n d i n g the
same conference was reimbursed $ 1,062 f o r the t r i p .
TABLE 2
Posit ion
ARIZONA SCHOOL FOR THE DEAF AND THE BLIND
TRUST FUND AND LOCAL FUND
TRAVEL EXPENDITURES BY POSITIONS
FOR FISCAL YEAR 1990- 91
( Unaud i t ed 1
Superintendent
Associate Superintendents
Di rectors
Assistant Directors
Principals
Administrative Staff
Other Professional and
Supervisory Personnel
Teaching Staff
Basketbal I ~ ournarnent(~)
Total
Percentage of
Trips Travel T rave l
Taken Expenditures Expenditures
( a) Basketball Tournament expenditures consist o f a i r f a r e f o r students and coaches and
reimbursement of meals f o r coaches.
Sou rce : ASDB financial records for fiscal year ended June 30, 1991.
The Board i s often unaware of such expenditures u n t i l a f t e r the fact, i f
at a l l . Board approval for the two t r i p s described above was not
obtained u n t i l a f t e r the travel expenses had been incurred. In another
case two PDSD s t a f f attended a conference at a cost of $ 1,750. The
School used local funds for t h i s t r a v e l , which was never approved by the
Board.
Some donations and local funds are ~ o o rmla~ na aed - Other problems exist
i n the management of donat ions and l oca l funds . The Super i n t enden t and
the Director of PDSD receive donations for t h e i r respective campuses. I f
not r e s t r i c t e d to a s p e c i f i c purpose by the donor, these administrators
allocate donations however they choose. This s i t u a t i o n has led to
questionable management of some donations by administrators as indicated
by the following examples.
The former Superintendent received a donation of $ 2,500 i n May 1990
that the donor designated for the work subsidy fund, a fund that
provides employment for students. The Superintendent diverted $ 1,000
of t h i s donation into the account he used to pay for community- based
events to promote the School's image. However, the Superintendent
does not have the authority to change the designated purpose of a
donation and i s legally responsible i f the donation i s used for a
purpose other than the one designated. Further, the donor or the
intended b e n e f i c i a r i e s o f the donation could enforce a claim against
the Superintendent or ASDB that the donation was used inappropriately.
In August 1989, ASDB received a bequest of $ 2,000 from an estate
d i s t r i b u t i o n . H i s t o r i c a l l y , bequests received by ASDB are deposited
into the t r u s t fund and invested. However, the former Superintendent
chose to spend t h i s bequest for out- of- state travel during t h a t year.
Administrators have also established and u t i l i z e d local funds without
oversight. The following are examples of two local funds with various
problems.
Curriculum materials fund - This fund was established to receive the
proceeds from the sale o f c u r r i c u l a developed by ASDB and sold to
other schools. The monies deposited in the fund were intended to be
used to pay for the cost o f d u p l i c a t i n g and d i s t r i b u t i n g c u r r i c u l a .
Although ASDB administrators u t i l ized these monies for a variety of
curriculum- related purposes, including out- of- state travel and
purchases of computer e uipment, they did so without the knowledge or
approval of the Board. ( 19
PDSD local funds - PDSD has several local funds with revenues from a
variety o f sources, including donations and receipts from school
a t h l e t i c events. These funds were established by the PDSD Director
who, in practice, has also exercised sole control over them without
any direction from the ASDB Superintendent or the Board. These funds
have been used for out- of- state travel for the PDSD Director and
other PDSD s t a f f and for purchases o f capital equipment without the
knowledge or approval of the Board.
Board Needs To Strenclthen
Controls Over Nonappropriated Funds
The Board should strengthen controls over nonappropriated funds.
Although the Board has established a policy that requires advance
approval of travel, i t should also i n s t i t u t e further controls over the
nonappropriated funds. As an alternative, the Legislature may wish to
consider making these monies subject to appropriation.
Board has established policy to reauire advance approval of travel - In
response to concerns about excess i ve travel , the Board changed i ts pol icy
to require approval of out- of- state travel in advance and on a
trip- by- trip basis. Until recently, the former Superintendent
apportioned the lump sum budgeted by the Board for out- of- state travel in
any way he chose. After the Board learned of plans for three
administrators and three teachers to attend a conference in Hawaii in
1991, they rejected the plans for the t r i p for the administrators. The
Board f e l t the t r i p to Hawaii for administrators was inappropriate at a
time of s t a f f layoffs. Prior to this event, the Board t y p i c a l l y approved
( 1 ) I n a d d i t i o n , ASDB's p r a c t i c e of depositing the proceeds of curriculum sales i n t o i t s
curricuium materiai s tund may be inconsistent w i t h State accounting procedures.
School curriculum development s t a f f are funded through General Fund appropriations. A
Department of Administration- Finance o f f i c i a l advi sed us t h a t monies generated from
a c t i v i t i e s funded by the General Fund should be deposited i n the General Fund.
out- of- state travel after i t occurred. Since then, the Board has
requi red administrators to seek approval from the Board before travel ing
out- of- state.
Other controls over nona~ propriated funds are inadeauate - Board policies
and controls over local funds and donations are deficient in several
additional areas.
The Board does not adequately review donations when they are received
to determine their most appropriate use or review how donations are
used. Although reviewing a l l donations upon receipt i s not practical
because most are small, the Board should review large donations ( over
$ 1,000) when they are received. The Board should also review the use
of a l l donations on a quarterly basis.
The Board does not approve the establ ishment of each fund or speci fy
the expenditures that can be made from the fund. Therefore, because
the Board does not control the transactions in a particular fund, i t
may not be aware of certain transactions.
The Board does not periodical ly review and approve the revenues and
expenditures of a l l nonappropriated funds quarterly, although i t is
s t a t u t o r i l y responsible for reporting a l l financial transactions of
the School to the Governor.
Appropriation of monies may be considered - I f the Board does not
establish meaningful oversight over donations and local fund monies, the
Legislature may wish to consider including them for appropriation in the
budget, since the expenditures made from these funds include out- of- state
travel and equipment purchases. A Senate b i l l was introduced in the most
recent l e g i s l a t i v e session that would have made donations subject to
appropriation by the Legislature, however, i t did not pass.
Appropriation of the trust fund earnings and local funds would enable
greater control over the use of these monies. For example, ASDB
out- of- state travel expenditures could be more closely monitored by the
Legislature, as is done with the travel expenditures of most other State
agenc i es .
RECOMMENDATIONS
1. The Board should establish s t r i c t policies and controls over the
expenditure of nonappropriated monies. The Board should also
a. Revise ASDB's travel policy to l i m i t the number of persons on
each t r i p , increase the travel allowance for teaching s t a f f , and
require j u s t i f i c a t i o n for each t r i p .
b. Approve use of donations over $ 1,000.
c. Review the use of donations under $ 1,000.
d. Approve the estabiisnment of local fund accounts, including
specifying the sources and uses of these monies.
e. Review and approve revenue and expenditure transactions
quarterly for a funds.
2. I f the Board cannot e f f e c t i v e l y oversee or control the use of the
donations and local fund monies, the Legislature may wish to consider
appropriating them.
FINDING Ill
ASDB HAS IMPROMD
STUDENT EVALUATION AND PLACEMENT
ASDB has done much since 1987 to improve the evaluation and placement of
students at ASDB. However, some problems i n placing m u l t i p l y handicapped
students remain to be addressed.
As part of our review of ASDB's student evaluation and placement process,
we surveyed local school d i s t r i c t o f f i c i a l s throughout the State and
parents of ASDB students. We also contracted with a team of experts in
the f i e l d of sensory- impaired education t o a s s i s t with our assessment of
the School's level of compliance with Federal and State regulations
concerning student evaluation and placement. The consultants examined a
representative sample of 178 student f i l e s ; reviewed 11 cases that had
been the object of complaints or disputes involving ASDB; and interviewed
representatives of ASDB, the Arizona Department of Education, and local
school d i s t r i c t s . ( ' )
ASDB's Evaluation And Placement
Process Has Markedlv Improved
Substantial progress has been made toward upgrading student evaluation
and placement at ASDB. Our previous review of ASDB revealed s i g n i f i c a n t
problems with the evaluation and placement process. Since then, steps
have been taken to address or ameliorate many of these problems.
1987 audit found major ~ roblems - Our Office f i r s t reviewed the
evaluation and placement process at ASDB in 1987. A t that time, we found
that ASDB made admission and placement decisions without involving local
schoc d i s t r i c t s . For example, Tucson Unified School D i s t r i c t personnel
were aware of only 6 of 104 students from their d i s t r i c t that were
( 1 ) The c o n s u l t a n t s ' r e p o r t i s a v a i l a b l e f o r review by i n t e r e s t e d i n d i v i d u a l s . Copies of
the report may be requested from the O f f i c e o f the Auditor General.
enrolled at ASDB. We found ASDB's admissions policy was inadequate
because i t did not include a system to involve school d i s t r i c t s i n the
r e f e r r a l and placement process at ASDB.
S i a n i f i c a n t im~ rovement has occurred - ASDB has addressed many of the
concerns raised i n our previous report and now encourages school d i s t r i c t
and parent involvement in the evaluation and placement process at
ASDB.(') For example,
To encourage d i s t r i c t involvement, ASDB has changed the way i t
schedules evaluation and placement meetings. Meetings for a
d i s t r i c t ' s students are now scheduled around the same time to make i t
more convenient for d i s t r i c t o f f i c i a l s to p a r t i c i p a t e .
N o t i f i c a t i o n of scheduled meetings has also improved. Although some
occasional problems s t i l l e x i s t , 95 percent of the parents we
surveyed said ASDB provided adequate notice of meetings scheduled for
t h e i r Almost 90 percent of school d i s t r i c t o f f i c i a l s
that had students evaluated at ASDB in the past three years reported
that ASDB rovided adequate n o t i f i c a t i o n of evaluation and placement
meet ings. t 37
Teleconferencing has been used in some instances when parents or
d i s t r i c t o f f i c i a l s were unable to attend.
ASDB now keeps d i s t r i c t s better informed of the students from their
d i s t r i c t s that are enrolled in ASDB programs. S t a f f a t both ASDB- Tucson
and PDSD have been assigned r e s p o n s i b i l i t y for keeping school d i s t r i c t s
informed of the students placed in their programs.
In addition to the School's e f f o r t s , statutes and p o l i c i e s have been
revised to require school d i s t r i c t involvement in student evaluation and
placement.
( 1 ) Despite ASDB's e f f o r t s , d i s t r i c t s do not always p a r t i c i p a t e in evaluation and
placement meetings. In reviewing student f i l e s a t ASDB- Tucson, the consultant team
found t h e s i g n a t u r e of school representatives on only 63 percent of i n i t i a l placement
forms and 72 percent of three- year reviews, although a d i s t r i c t representative i s
required to attend these meetings and sign these forms.
( 2 ) Questionnaires were sent to a s t a t i s t i c a l l y valid sample of 233 parents. Completed
surveys were received from 177 parents, f o r a response rate of 76 percent.
( 3) Surveys were also sent to a l l 233 local school d i s t r i c t special education d i r e c t o r s .
Completed surveys were received from 159 d i s t r i c t s , for a 68 percent response r a t e .
Ninety respondents reported that students from thei r d i s t r i c t had been evaluated a t
ASDB in the past t h r e e y e a r s .
Arizona Revised Statutes ( A. R. S.) 915- 1342. was amended in 1988 to
require that school d i s t r i c t o f f i c i a l s d i r e c t the evaluation and
placement process and p a r t i c i p a t e i n evaluation and placement
meetings at ASDB.
ASDB developed a new admissions policy i n 1989 that r e q u i r e s ' a l l
r e f e r r a l s for evaluation and placement in ASDB programs to be made
through the student's d i s t r i c t of residence. The policy also
establishes guidelines f o r evaluation and placement that require
collaboration between ASDB and the local school d i s t r i c t .
ASDB's Board of Directors also established a policy expressing ASDB's
commitment to serve only those students that cannot be adequately
served in a regular classroom with the use of supplemental aids and
services.
The consultant team that assisted with our review reported that ASDB has
made " enormous strides i n the past f i v e years." These consultants found
no major flaws i n the evaluation and placement process.
Placement Of Multiply Handica~ ped Students
Continues To Generate Controversy
Problems continue i n placing students w i t h m u l t i p l e handicaps. Since
1987, ASDB has expanded i ts programs to serve sensory- impai red, mu I t i p ly
handicapped students. However, placement of these students s t i l l
generates some controversy, and the factors generating controversy need
to be addressed. Services for sensory- impaired students with severe
emotional disorders also need to be developed to ensure compliance with
Federal requirements.
Services to m u l t i p l v handicap~ ed students expanded since 1987 - Programs
for m u l t i p l y handicapped students at ASDB have increased since 1987. Our
previous report recommended that ASDB expand e f f o r t s to meet the needs of
sensory- impaired students with additional handicaps. In many instances,
ASDB was found to be better suited to provide programs for these students
than local d i s t r i c t s . However, at that time ASDB appeared to be
reluctant to serve multiply handicapped students. ASDB has taken a
number of steps to expand services for m u l t i p l y handicapped students
since 1987. The number of educational classes for m u l t i p l y handicapped,
severely sensory- impaired ( MHSSI) students at ASDB's Arizona Diagnostic
Testing and Education Center ( ADTEC) in Tucson was increased from f i v e to
seven. In addition, two classes for MHSSl students were established at
the Phoenix Day School for the Deaf. The North Central Regional
Cooperative, which began operating in 1989, also serves 23 MHSSl students.
Placement of m u l t i ~ l vh andicaoped students continues to create problems -
Although ASDB has expanded programs for multiply handicapped students,
placement of these students s t i l l creates problems. In interviews with
the consultant team and in responses to our survey, some school d i s t r i c t s
expressed concerns about ASDBts willingness to accept multiply
handicapped students as indicated by the following responses:
ASDB needs to accept in their program in Tucson students who are
severe in nature. I t has been my experience that they have only
taken those students that offer minimal challenge to them.
Although things have improved recently, ASDB has not wanted to
accept students who are handicapped ( i n addition to the sensory
impairment). The strange outcome is that ASDB tends to take the
less severely handicapped students, while the public schools
take the more complex students.
The reason we do not refer many students to ASDB programs i s
because h i s t o r i c a l l y they do not accept our referred students
who have " other" disabi l i t i e s .
Some local d i s t r i c t s have f i l e d complaints with the Arizona Department of
Education ( ADE) regarding the evaluation and placement of students at
ASDB. Members of the consultant team reviewed 11 complaints i d e n t i f i e d
by ADE and found that these cases t y p i c a l l y involved students with
" extremely challenging problems requiring the design of individualized
educational and other intervent ion programs."(')
Factors leadinq to problems need to be addressed - Several factors appear
to be responsible for the controversies involving multiply handicapped
students.
( 1 ) The c o m p l a i n t s c o n c e r n i n g ASDB p r i m a r i l y i n v o l v e d sensory- impaired students w i t h
severe emotional d i s o r d e r s , mental r e t a r d a t i o n , o r l i m i t e d E n g l i s h p r o f i c i e n c y .
ASDB's role i n serving sensory- impaired students with additional
handicapping conditions i s unclear. ASDB statutes c o n f l i c t and may lead
to disputes over which students the School should serve. Some school
d i s t r i c t representatives and ADE o f f i c i a l s believe that ASDB i s required
to serve all sensory- impaired students that cannot be served by t h e i r
d i s t r i c t of residence. An ADE o f f i c i a l c i t e d Arizona Revised Statutes
( A. R. S.) $ 15- 1343( A):
A person i s e n t i t l e d to an education in the school for the deaf
and the b l i n d without charge i f he i s a resident of the state,
age s i x to twenty- one years and sensory impaired to an extent
that he cannot acquire an appropriate education i n the school
d i s t r i c t of residence.
ASDB, i n contrast, has argued that the School i s only part of a continuum
of services required by sensory- impaired students. A. R. S. $ 15- 1342( F)
provides some support for t h i s p o s i t i o n :
I f the chief administrator of the school or accommodation school
or his designee and the superintendent of the school [ ASDB]
determine that the school [ ASDB] cannot provide the appropriate
educational programs and services needed by the c h i l d , they
shall locate or establish a program to meet the c h i l d ' s needs i n
consultation with the department of education and any other
appropriate state agency.
The cost of serving sensory- impaired students t h a t are m u l t i p l y
handicapped may also generate controversy over who w i I I serve these
students and who w i l l pay for services. ASDB and ADE o f f i c i a l s agree
that current funding levels do not match the cost of serving special
education students. An ASDB o f f i c i a l has said that t h i s makes i t
d i f f i c u l t for them to add new students during the year. For f i s c a l year
1990- 91, ASDB received $ 12,210 from i n s t i t u t i o n a l voucher payments for
each student c l a s s i f i e d as MHSSI. However, ADE reports that ASDBrs per
pupi I cost for MHSSI students was $ 31,451 for the same period.
The problems associated with serving m u l t i p l y handicapped students cannot
be resolved by ASDB alone. In November 1991, representatives of ASDB met
with ADE o f f i c i a l s to discuss the complaints received by ASDB. In
January 1992, ASDB and ADE established a voluntary task force to review
ASDB's admissions policy and role. Although the group discussed several
issues, many remain unresolved, and add i t ional measures are needed to
reduce controversy over ASDBts role. A more formalized task force needs
to be established by the Legislature to examine ASDBts role i n serving
sensory- impaired, m u l t i p l y handicapped students and the adequacy of
current funding levels. The task force should be directed by ADE and
include representatives of ASDB, local school d i s t r i c t s , and the
Department of Health Servicest Behavioral Health Division. In addition,
l e g i s l a t i v e action may be needed to c l a r i f y ASDB's statutory role and
address current funding problems.
Prwram for students with severe emotional disorders needed - Arizona may
not comply with Federal requirements because i t lacks some necessary
services for sensory- impaired students with severe emotional disorders.
In recent years, several sensory- impaired students with severe emotional
disorders have been referred to ASDB for placement. ASDB and local
school d i s t r i c t s have found these students d i f f i c u l t to serve because
they may exhibit aggressive behaviors that necessitate placement i n a
hospital or residential treatment s e t t i n g . In addition, these students
require the services of trained counselors and therapists that are also
s k i l l e d i n working with the sensory- impaired.
Arizona currently lacks some services for sensory- impaired students with
severe emotional disorders. According to our consultants, the State does
not have psychiatric treatment f a c i l i t i e s designed to handle
sensory- impaired students with severe emotional disorders. A recent
report by the Statewide Behavioral Task Force on Deafness also indicates
Arizona does not have adequate behavioral health services for the deaf
and hard of hearing. As a r e s u l t , the State may not comply with Federal
special education requirements. The Federal Individuals with D i s a b i l i t y
Education Act ( IDEA) requires that states provide a l l c i t i z e n s w i t h a
free, appropriate education. I n a d d i t i o n , IDEA requires that states have
a f u l l range of placement options available.
ASDB has recognized the need to improve services for t h i s population of
students.(') However, providing services to sensory- impaired students
with severe emotional disorders can be costly. According to our
consu l tants , schoo l - based programs can cost between $ 60,000 and $ 120,000
per pupi I annually, and hospital- based programs can cost over $ 1,000 per
day.( 2) To date, ASDBfs e f f o r t s to establish a special program have been
unsuccessful. Development of such services w i l l require additional
funding and the active p a r t i c i p a t i o n of ADE, ASDB, local school
d i s t r i c t s , and the Department of Health Services' Behavioral Health
Division.
( 1) ASDB submitted a grant proposal to the U. S. Department of Education seeking funds f o r
a j o i n t program w i t h a Tucson p s y c h i a t r i c hospital . The School has also worked to
obtain funding f o r the program through the Department of Health Services' Behavioral
Health D i v i s i o n .
( 2 ) Currently, one Arizona student i s i n an I l l i n o i s program f o r hearing- impai red students
w i t h severe emotional disorders. This student was placed i n a h o s p i t a l s e t t i n g f o r 60
days a t an average cost of $ 1,335 per day. The student i s now i n the program's
therapeutic group home a t a cost of $ 212 t o $ 262 per day.
RECOMMENDATIONS
ASDB should continue i t s e f f o r t s to improve the evaluation and
placement process. S p e c i f i c a l l y ,
The School should take steps to ensure i t consistently complies
with the statutes and regulations governing student evaluation
and placement, and
ASDB should work to achieve f u l l parental and school d i s t r i c t
p a r t i c i p a t i o n i n the evaluation and placement process.
The Legislature should establish a task force to address problems
concerning the placement of m u l t i p l y handicapped students. The task
force should be led by ADE and include representatives from ASDB,
local school d i s t r i c t s , and the Department of Health Services'
Behavioral Health Division. S p e c i f i c a l l y , t h i s group should
Clar i fy ASDB's role i n serving sensory- impai red students with
multiple handicaps and severe emotional disorders.
Examine the adequacy of funding levels for sensory- impaired
students w i t h m u l t i p l e handicaps.
Determine the need for and type of special programs for sensory
impaired students with severe emotional disorders.
Develop recommendations and report findings to the Legislature
Based on the recornendations of the task force, the Legislature
should consider revising ASDB's statutes to c l a r i f y the School's role
i n serving the sensory impaired.
FINDING IV
THE BOARD NEEDS TO IMPROVE ITS GOVERNANCE
OF THE ARIZONA SCHOOL FOR THE DEAF AND THE BLIND
The Board of D i r e c t o r ' s oversight and control of the Arizona School for
the Deaf and the Blind ( ASDB) needs strengthening. In recent years,
s i g n i f i c a n t leadership and financial management problems have developed
without the Board's knowledge. Although the Board has taken some steps
to improve i t s oversight and control of ASDB, further action i s needed to
ensure e f f e c t i v e governance.
The statutes assign primary r e s p o n s i b i l i t y for proper operation of ASDB
to the Board o f D i r e c t o r s . Although the Board hires a Superintendent to
provide day- to- day management of the school, the Superintendent has very
few d i r e c t s t a t u t o r y r e s p o n s i b i l i t i e s other than to h i r e other School
personnel. A l l other major r e s p o n s i b i l i t i e s ( v i z . , budget development
and approval, control of expenditures of appropriated funds,
establishment of personnel p o l i c i e s , development of c u r r i c u l a and
programs, disposition of t r u s t lands, and control over t r u s t fund
investments and expenditures) rest with the Board.
Board Oversiqht
And Control Is Weak
Because the Board o f D i r e c t o r s ' oversight and control of ASDB operations
i s weak, s i g n i f i c a n t management and financial problems have arisen
without the Board's knowledge. The Board lacks the p o l i c i e s and
procedures needed to guide s t a f f and secure the information necessary to
d i r e c t School operations e f f e c t i v e l y . I n e f f i c i e n t and unproductive Board
meetings a l s o c o n t r i b u t e to inadequate governance.
The Board was unaware of ~ roblems - U n t i l informed by l e g i s l a t o r s in July
1991, ASDB Board members state they were unaware of the serious
d i s s a t i s f a c t i o n of ASDB s t a f f , parents, and some l e g i s l a t o r s w i t h the
former Superintendent's management of ASDB.(') Matters contributing to
d i s s a t i s f a c t i o n w i t h ASDB leadership in 1991 include the following:
Concerns about an excessive number of administrators
Reducing services to students but not administrators during a major
reduction i n force
a Funding of administrators' frequent travel t o out- of- state conferences
Frequent a i r travel from Tucson to Phoenix and rental of luxury cars
in Phoenix by the former Superintendent
Problems with s t a f f morale and management communication
The former Superintendent's request to the Legislature, without the
Board's knowledge, for postponement u n t i l 1994 of the 1991- 1992
Sunset Audit of ASDB
Inclusion of a $ 54,000 clock tower in construction plans for the
Tucson campus, in spite of the objections of s t a f f , parents, and
legislators
After being informed of these problems, the Board met several times to
address the s i t u a t i o n . During t h i s time, the Superintendent relinquished
his position and was reassigned as the Board's Project Specialist. The
former Superintendent served in this posit ion at a salary of $ 74,500 from
July 1991 to June 1992. The pos i t i on was funded using savi ngs from the
vacant Superintendent position.
Performance of Former Superintendent not evaluated - Many of the problems
might not have developed i f the Board had more actively monitored and
evaluated the performance of the former Superintendent. According to
BOARDSMANSHIP, the manual for school boards pub1 ished by the Arizona
School Boards Association, evaluation of the Superintendent is one of a
board's most powerful tools for managing a school in the public
interest. However, in four of the five years preceding the ASDB
Superintendent's removal in 1991, the Board did not formally evaluate his
performance.
( 1) The Board was also unaware of the questionable expenditures of nonappropriated funds
we found during t h i s audit ( see Finding 11, page 19).
Policv auidance i s lacking - Although part- time, the Board could exercise
more oversight by developing better operating p o l i c i e s for the s t a f f and
school .
According to the BOARDSMANSHIP manual, a school board i s responsible for
adopting p o l i c i e s under which administrators and teachers may operate the
school. Although Boards should not be involved i n the day- to- day
management of the school, they should, through p o l i c i e s , provide clear
d i r e c t i o n for the administration of the school. Among p o l i c i e s needed,
the manual states, i s a w r i t t e n communications policy that provides for a
planned, systematic, two- way program of comunication between the
i n s t i t u t i o n and i t s internal and external publics.
As yet, the Board has no w r i t t e n communications p o l i c y t o ensure a
systematic d i a l o g w i t h i t s internal publics ( ASDB administrators, s t a f f ,
students) or i t s external publics ( students' parents, advocacy groups,
the Legislature, the media). The need for a communications policy i s
p a r t i c u l a r l y important because the policy in force p r i o r to August 1991
was perceived as p r o h i b i t i n g s t a f f input to the Board.
Furthermore, the Board provides ASDB administrators and s t a f f r e l a t i v e l y
l i t t l e other w r i t t e n policy guidance, except on personnel matters,
compared to the policy guidance provided at s i m i l a r , highly regarded
special schools in other states or at an e f f e c t i v e l y managed Arizona
pub1 i c school . ( ' ) ASDB Board p o l i c i e s , for example, provide l i t t l e of
the extensive policy guidance provided at other schools regarding
curricula and instruction, student behavior and r e s p o n s i b i l i t i e s , general
school administration, educational philosophy, provision of support
( 1 ) To evaluate the scope o f p o l i c y d i r e c t i o n provided ASDB, we compared p o l i c y manuals o r
p o l i c y manual i n d i c e s o f h i g h l y regarded special schools i n several o t h e r s t a t e s , as
w e l l as t h e N a t i o n a l School Boards A s s o c i a t i o n pol i c y c l a s s i f i c a t i o n system index and
the index o f the p o l i c y manual of the Mesa pub1 i c schools, which employs the NSBA
system, w i t h the ASDB manuals.
services, relations with other agencies, or communications and community
relations. In addition, the Board has not adopted policies for i t s
operations except for the election o f o f f i c e r s and attendance, the later
of which has not been enforced.
Board meetinas also contributed to aovernance ~ r o b l w s- I n e f f i c i e n t and
unproductive Board meetings also limited the Board's a b i l i t y to govern.
During our i n i t i a l interviews, Board members expressed dissatisfaction
and f r u s t r a t i o n w i t h the Board's procedures and accomplishments. They
noted that meetings focus more on " housekeeping" than on important policy
issues. Our review and analysis of the minutes of 28 regular Board
meetings held from July 1989 through February 1992, and observation of
Board meetings over a six- month period confirms this.
Although much of the Board's emphasis on routine matters is the result of
i t s attempts to exercise greater control over school a f f a i r s , the Board's
effectiveness in these e f f o r t s is limited by the lack of policies and
procedures governing their review and Board members1 i n a b i l i t y to review
information prior to the meeting.
As a result, Board meetings ( which usual ly consist of a pub1 ic study
session, closed executive session, and a public meeting) t y p i c a l l y last
about four hours and, frequently, as long as five or six hours. When
Board meetings habitually exceed two and one- half hours, the
BOARDSMANSHIP manual states the reason for this is either consideration
of administrative items more properly the province of school
administrators or inadequate preparation by Board members. Both problems
appear to contribute to the excessive length of ASDB Board meetings.
ASDB Board a c t i v i t i e s focus predominantly on routine business and
personnel matters, and some Board members residing outside Tucson
complain that information packages frequently arrive too late to permit
review before meetings.
Action To lm~ rove
Governance Is Needed
Although the Board has taken some steps to address i t s governance
problems, further action is needed. I f governance is not improved
through the Board's e f f o r t s , other governance systems should be
considered.
The Board has beaun to address aovernance oroblems - In recognition of
the Board's problems i n governing ASDB, many of which Board members
discussed candidly with us, the Board has taken some steps to improve
governance. For example, the Board in i t s public study sessions includes
discussion of upcoming Board agenda items, c a l l s routinely for public
comment on issues during i t s regular meetings, and requires separate
readings at successive monthly meetings before acting on the most
important issues i n order to promote dialog with s t a f f , students,
parents, and the public. To enhance dialog, the Board has rescinded a l l
r e s t r i c t i o n s on s t a f f communications with Board members. The Board also
contracted for Arizona School Board Association assistance i n conducting
the search for a new Superintendent. The Board has also completed a
Request for Proposal ( RFP) for outside help i n preparing a comprehensive
policy manual. However, funding has not been obtained. In addition, the
Board investigated the p o s s i b i l i t y of an outside review of ASDB
management needs, but the review is being held in abeyance pending
completion of t h i s audit. F i n a l l y , the Board brought some t r u s t fund
expenditures under i t s direct control.
Further action i s reauired - The Board needs to follow through on some of
the tentative steps i t has already taken as well as take additional
measures to govern ASDB more e f f e c t i v e l y . Among actions the Board should
take are the following additional measures.
Secure and commit the resources needed to develop a comprehensive,
codified policy manual to guide ASDB administrators and s t a f f .
Develop and publish bylaws that include prompt and regular
attendance, and conduct i t s meetings in accordance with them.
Improve i t s oversight of the Superintendent and regularly evaluate
his or her performance.
Improve i t s oversight and control of nonappropriated funds ( see
Finding I I ).
Ensure that i t s members receive the training needed to conduct Board
meetings e f f e c t i v e l y .
Ensure that Board members have information packets at least seven
days before the Board's regular public meetings.
Other aovernance svstems are possible - I f governance i s not improved by
the Board's e f f o r t s , other governance systems could be considered. There
are a v a r i e t y o f service delivery models for sensory- impaired pupils and,
according to our consultants and Federal o f f i c i a l s , highly regarded
special schools function within each model. Most of these special
schools operate under the d i r e c t i o n of t h e i r states' board of education;
however, s p e c i f i c a l l y appointed boards, such as the ASDB Board, d i r e c t
the operation of these special schools in 14 states. In three states,
these special schools operate under the d i r e c t i o n of the state board of
regents.
RECOMMENDATIONS
1. The Board should develop a comprehensive set of operating p o l i c i e s t o
guide i t s a c t i v i t i e s and ASDB's a c t i v i t i e s .
2. The Board should thoroughly evaluate the Superintendent's performance
each year.
3. The Board should ensure that i ts members receive the t r a i n i n g needed
to perform t h e i r duties e f f e c t i v e l y .
4. The Board should ensure that every member receives information for
i t s meetings in time to review the information before the meetings.
FINDING V
ASDB'S ROLE AS A STATEWIDE RESOURCE
IS NOW CLEARLY ESTABLISHED IN STATUTE; HOWEVER,
MORE NEEDS TO BE DONE TO FULFILL THIS MANDATE
Although ASDB now provides some services to local school d i s t r i c t s ,
additional e f f o r t s are needed to f u l l y develop the School's role as a
statewide resource. Since our 1987 audit, ASDB's statutes have been
amended to require that the School serve as a resource to local school
d i s t r i c t s throughout Arizona. ASDB has worked with d i s t r i c t s in north
central Arizona to develop a successful regional cooperative program for
sensory- impaired students. In addition, ASDB has provided a limited
quantity of resource services to school d i s t r i c t s ; however, these
services should be expanded.
ASDB Is Now Reauired To Serve As A
Resource To Local School Districts
ASDB's role in providing resource services to the public school community
i s now c l e a r l y established. In our 1987 report, we found that ASDB could
further develop i t s role as a statewide resource i n the education of the
sensory impaired. Since 1987, ASDB's statutes have been revised twice to
require t h a t ASDB provide resource services to local school d i s t r i c t s .
In 1987, l e g i s l a t i o n was passed that c a l l e d f o r the establishment of a
p i l o t program of regional cooperative services to be operated by ASDB.
The program was to provide a variety of services for p a r t i c i p a t i n g
d i s t r i c t s . In 1990, ASDB's statutes were again amended to mandate that
ASDB provide a number of services to school d i s t r i c t s , State i n s t i t u t i o n s
and other approved education programs. These changes establishing ASDB's
role as a resource to local school d i s t r i c t s are important for several
reasons.
Federal law requires that sttldents he placed in the least r e s t r i c t i v e
environment. Public Law 94- 142 presumes that disabled children w i l l
be educated with nondisabled children, unless these children cannot
be educated s a t i s f a c t o r i l y i n regular classes with the use of
supplementary aids and services. ASDB can o f f e r services that allow
d i s t r i c t s to serve some students that would otherwise be placed out
of d i s t r i c t .
ASDB can offer specialized services for the sensory- impaired that are
difficult for some districts to provide because of geographic factors
and the small number of sensory- impaired students. The 1988 Arizona
School Superintendent's Special Education Services Study found that
rural districts are typically small and often lack the resources to
offer an effective and efficient special education program.
ASDB has expertise in the education of sensory- impaired students that
some districts may lack. School districts sometimes find it
difficult to attract personnel that are trained to work with
sensory- impaired students because they may need staff on a part- time
or limited- term basis.
Finally, ASDB has facilities for the sensory- impaired that districts
may be unable to provide. Our consultants found that ASDB has
outstanding facilities for both hearing- impaired and
visually- impaired students.
Pilot Reqional Coo~ erative Proqram Has Been
Successful And Should Be Ex~ anded
The pi lot regional cooperative program administered by ASDB has shown
.. ne ; t, ,; ,,, m, resu! t s and shou! d be expanded. The program was establ ished in
north central Arizona in 1987 and has proven to be beneficial. As a
result, the ASDB Board of Directors should consider extending the program
to other areas of the State.
Overview of the ~ ilot reqional coo~ erative proaram - A pi lot regional
cooperative program was established by Senate Bill 1251 in 1987. This
legislation called for the creation of three regional service
cooperat i ves in f i sca I year 1987- 88 . ( ' I These cooperat i ves were to be
operated by ASDB through intergovernmental agreements with participating
school districts, and were to provide a variety of services, including
the following:
Educational programming
Evaluations, including audiological, psychological, and vision
assessments
Specialized related services, including orientation and mobility
training
( 1 ) The p i l o t program was o r i g i n a l l y scheduled to operate through f i s c a l year 1989- 90;
however, in 1990 i t was extended through f i s c a l year 1993- 94.
Specialized curriculum materials and equipment
Program and s t a f f development assistance
Assistance with screening, i d e n t i f i c a t i o n , and r e g i s t r a t i o n of
sensory- impai red pupi Is
In 1988, the State Board of Education determined that regional
cooperative programs would operate in north central, southeast, and
southwest ~ r i z o n a . ( ' ) Due to resource constraints, funding was provided
for the establishment of only one regional cooperative. The north
central region was selected as the pi l o t region because of the lack of
services i n that area and because of the a c t i v e i n t e r e s t shown by parents
and school d i s t r i c t s t o improve services.
The North Central Regional Cooperative began operating i n the f a l l of
1989. As of February 1992, 31 local school d i s t r i c t s were p a r t i c i p a t i n g
in the Cooperative, which was providing educational services to 84
students.
Pilot Droaram has been successful - The p i l o t regional cooperative
program has been quite successful during i t s f i r s t three years of
operation. Parents of students i n the North Central Regional Cooperative
have expressed high levels of sat isfact ion with the program. Ninety- one
percent of the parents responding to our survey favored continuing the
program(*), and a majority indicated their children are receiving a wider
range of special services, are spending more time receiving services, and
are receiving a higher q u a l i t y of services since the program was
established. Many parents commented on the benefits of the program. A
sample of t h e i r comments follows.
( 1 ) The n o r t h c e n t r a l r e g i o n i n c l u d e s most o f Yavapai , Coconino, and n o r t h e r n Mohave
Counties. The southeast r e g i o n i n c l u d e s the Tucson metropol i tan area, and Graham,
Cochi se, Santa Cruz, and southern Greenlee Counties. The southwest r e g i o n i n c l u d e s
Yuma and southern La Paz Counties.
( 2 ) As p a r t of o u r r e v i e w , q u e s t i o n n a i r e s were sent t o the parents of a l l 72 students then
r e c e i v i n g services through the Cooperative. Completed surveys were r e c e i v e d from the
parents of 64 students, f o r a response r a t e o f 89 p e r c e n t .
The services being provided would not be made available without
the ASDB Cooperative Program. The School does not have
personnel and/ or equipment to provide s a t i s f a c t o r i l y for
visually- disabled students. Guidance from s p e c i a l i s t s i s needed
and should be continued.
Since our son started junior high t h i s year, and started
receiving help, he has started to enjoy reading and school. His
grades were a l l A's and B's on h i s last report card. I cannot
praise the program enough.
Before t h i s program, we had to personally f i g h t for every
service our daughter needed to compensate for her hearing loss.
Now we have knowledgeable and supportive personnel and the
services are available as needed.
School d i s t r i c t o f f i c i a l s also appear to strongly support the program.
We surveyed local o f f i c i a l s from the North Central Regional Cooperative
regarding the program.(') Of those respondents that expressed an
opinion, a l l believed the program should be continued. In addition, many
d i s t r i c t o f f i c i a l s indicated they would have d i f f i c u l t y providing
comparable services on t h e i r own. The high level of p a r t i c i p a t i o n i n the
North Central Regional Cooperative also indicates the program i s
b e n e f i c i a l t o local school d i s t r i c t s . Although involvement i n the North
Central Regional Cooperative i s voluntary, most d i s t r i c t s within the
region's boundaries are p a r t i c i p a t i n g in the program. In addition, four
school d i s t r i c t s outside the region have joined the Cooperative or
receive services through the program.
The program's success i s also indicated by the increased number of
students served. North Central Regional Cooperative s t a f f have
i d e n t i f i e d sensory- impaired students that had not previously been served
or were underserved. Prior to the establishment of the North Central
Regional Cooperative, 63 pupils within the north central region were
c l a s s i f i e d as sensory impaired. During the f i r s t year of the program,
Cooperative s t a f f i d e n t i f i e d 49 additional students with hearing or vision
( 1 ) Surveys were sent to the Special Education Directors i n the 31 local school d i s t r i c t s
t h a t a r e members of the North Central Regional Cooperative. Surveys were returned by
22 d i s t r i c t s , for a response rate of 71 percent.
loss. In addition, Cooperative personnel found that 18 of the 63
students c l a s s i f i e d as sensory impaired were not receiving needed
services p r i o r to the program. These children were enrolled i n a school
d i s t r i c t program without a special teacher for the hearing or v i s u a l l y
impai red.
The reaional c o o ~ e r aitv e proqram should be exaanded - Regional service
cooperatives should be established i n the southeast and southwest regions
of the State. Monies saved from the elimination of unnecessary
administrative positions ( see Finding I, page 7) could be used to cover
the base- level administrative costs of adding two more regional
cooperative programs, which ASDB estimates to be $ 291,300.
Services Provided To Local School Districts
Are Limited And Should Be Increased
Although ASDB has provided some services to local school d i s t r i c t s , these
services need to be expanded. In addition to d i r e c t services to students
provided through the regional cooperative program, statutes also require
ASDB to provide a wide range of resource services to school d i s t r i c t s and
other educational i n s t i t u t i o n s in Arizona. However, to date ASDB's
e f f o r t s have been limited. More needs to be done i f ASDB i s to f u l f i l l
i t s mandate as a resource to local school d i s t r i c t s .
Am i s required to arovide a v a r i e t y of resource services - In 1990,
ASDB's statutes were amended to require the School to serve as a
statewide resource i n the education of the sensory impaired ( ASDB
requested t h i s change). Arizona Revised Statutes ( A. R. S.) 915- 1302( D)
requires ASDB to provide a wide range of resource services, including but
not limited to the following:
Assessments
Special curriculum
Equipment and materials
Supplemental related services
Special short- term programs
Program planning and s t a f f development
Information services for parents, families, and the public
Research and deve l opment to promote improved educat i ona l programs and
services
ASDB i s to provide these services to school d i s t r i c t s , State
i n s t i t u t i o n s , and other approved educational programs.
Limited resource services have been ~ r o v i d e d - Although ASDB has provided
some services to local school d i s t r i c t s , programs have yet to be
developed f u l l y i n many services areas. ASDB provides several types of
assessment services to local school d i s t r i c t s . ( ' ) The School has also
developed specialized curriculum materials that are available to s c h o ~ l
d i s t r i c t s . However, ASDB s t i l l needs to expand or develop many services,
including the following:
Evaluation services - A needs assessment conducted by ASDB in 1991
found that student evaluation i s the resource service most needed by
school d i s t r i c t s . However, ASDB has been unable to keep up with the
demand for these services. Our survey of local school d i s t r i c t s
found that some d i s t r i c t s have been placed on a waiting l i s t for
evaluation services. In addition, two d i s t r i c t s reported they had
been refused evaluation services by ASDB. The consultant team
reports that additional resources would need to be allocated t o
ensure that student evaluation services are provided i n a timely
fashion.
Special short- term proqrams - Our consultants recommend that " serious
consideration should be given to expanding ASDB on- campus programs to
a full- year program either by summer programming or short- term
intensive i n s t r u c t i o n for students who wouldn't be enrolled f u l l
time." The consultant team notes that ASDB could o f f e r programs in
o r i e n t a t i o n t r a i n i n g , B r a i l l e , computers, and American Sign Language.
Providina needed equiment and materials - The North Central Regional
Cooperative has a materials and equipment center in i t s Flagstaff
o f f i c e that supplies materials to teachers in the region. ASDB's
Acting Superintendent has suggested establishing such a program on a
statewide basis. Equipment used by sensory- impaired students, such
as Brai l le writers and auditory trainers, could be purchased by ASDB
( 1) The School ' s Arizona Diagnostic Testing and Education Center ( AOTEC) performs in- depth
nine- week evaluations o f sensory- impai red students w i t h addi ti onal handicapping
condi ti ons . ASDB a1 so conducts r o u t i n e student evaluations , c a l l ed Pub1 i c School
Assessments ( PSAs), f o r school d i s t r i c t s t h a t l a c k the expertise t o evaluate
sensory- impai red students themselves.
or cot
d i s t r i
serve
Brai I I
lected from d i s t r i c t s that no longer need i t and distributed to
cts with a demand for this equipment. The center could also
as a clearinghouse for teaching materials, such as books in
e and audio- visual materials.
In addition, ASDB has made l i t t l e progress in creating s t a f f development
programs for local school d i s t r i c t personnel or public information
programs. The School also made l i t t l e progress in providing supplemental
related services, such as orientation and mobility training, to students
in school d i s t r i c t programs.
School o f f i c i a l s c i t e resource constraints as the primary reason more
se rv i ces have not been rov i ded . ( ' ) However , the cost sav i ngs r ea l i zed
by eliminating nonessential administrative positions may provide funding
for expanded services to local d i s t r i c t s ( see Finding I, page 7).
RECOMMENDATION
1. ASDB's Board of Directors should consider the fol lowing steps to
f u l f i l l the School's mandate as a statewide resource.
a. Expand the regional cooperative program to the southeast and
southwest regions of the State.
b. Expand existing programs and develop new programs requi red by
A. R. S. $ 75- 1302( D).
c. Request the Legislature to allow savings generated from the
elimination of administrative positions be used to fund these
programs.
( 1 ) I n 1990, ASDB estimated i t would cost $ 250,000 t o develop resource s e r v i c e s .
FINDING VI
ASDB NEEDS TO COLLECT MORE
COMPREHENSIVE INFORMATION ABOUT ITS STUDENTS'
POST GRADUATION SUCCESS
The ASDB should increase i t s e f f o r t s to evaluate the success of i t s
graduates i n postsecondary employment and education. Evaluating student
outcomes i s an important measure of the School's success i n preparing
sensory- impaired students to lead f u l l , meaningful l i v e s . To date, ASDB
has collected only limited information about student a c t i v i t i e s a f t e r
graduation. Although the School has recently expanded follow- up of
graduates, i t needs to collect more systematic and comprehensive data.
Information About Student Outcome Is
An lm~ ortant Manaaement Tool
The success of ASDB graduates i s an important measure of the School's
performance. Arizona law establishes specific goals for the School. In
addition, parents and governing Board members also have expectations of
the School, p a r t i c u l a r l y in the areas of academic and vocational
preparation. These expectations are a l s o r e f l e c t e d in professional
l i t e r a t u r e .
Statutorv reauirements - Arizona law establishes d e f i n i t e expectations of
ASDB. A. R. S $ 15- 1302( B) provides: " The school shall be for the
education of sensory impaired persons, so that the persons educated there
may become self- sustaining and useful c i t i z e n s . " The Legislature further
expanded on the School's purpose in 1988 when i t added:
The purpose of the Arizona state school for the deaf and the
b i ind is to promote and maintain an educational opportunity of
adequate scope and q u a l i t y for sensory impaired children i n t h i s
state which w i l l lead to an adult l i f e of independence and
self- sufficiency, a meaningful personal, family and community
l i f e and, a useful productive occupational l i f e .
These goals, which are also included i n the School's mission statement,
require some type of follow- up. Without tracking students' progress
a f t e r graduation, the School cannot ascertain whether i t i s meeting i t s
goals.
Other ex~ ectations - Some parents of ASDB students also have d e f i n i t e
expectations about t h e i r c h i l d r e n ' s c a p a b i l i t i e s . Approximately 10
percent of the ASDB parents responding to our survey expressed concern
about t h e i r children's a b i l i t y to successfully compete a f t e r graduation.
Typical comments included the following:
I ' v e been pleased by [ my daughter's] progress i n many areas, yet
the world i s predominately hearing and unfortunately our kids
must l i v e mostly by their rules. To be taught how to cope i n
that world would be most b e n e f i c i a l .
Everyone i s & KJ s a t i s f i e d with accepting old [ ideas] regarding
education of the deaf. Students and faculty w i l l l i v e up to the
expectations set for them. I f these are low, t h e y ' l l respond
accordingly. ( emphasis in o r i g i n a l )
The parents' concerns are echoed by ASDB Board members' observations that
the School's expectations are too low, allowing students to graduate with
only marginal s k i l l s . These Board members want the Board to adopt
p o l i c i e s that w i l l lead to a more challenging, results- oriented education
for ASDB students.
Professional education l i t e r a t u r e also emphasizes student a b i l i t y to
succeed a f t e r graduation. One recent study of school- to- work t r a n s i t i o n
of deaf school graduates states:
Competitive employment has been viewed as the most desirable
outcome of the t r a n s i t i o n process, coupled with the capacit to
l i v e independently, socialize and engage in community l i f e . cur
( 1 ) Thomas E. A l l e n , Brenda W. Raslings, and A r t h u r N. S c h i l d r o t h , Deaf Students and the
School- to- Work T r a n s i t i o n ( B a l t i m o r e , MD: Paul H. Brooks Pub1 i s h i n g , C O . , I n c . , 1989),
page i x .
In addition, recent trends indicate that special education programs are
increasingly l i k e l y t o be evaluated i n terms of student a b i l i t y to
succeed i n a postschool environment. of the special education
outcome models presented i n a recent report from the National Center for
Educational Outcomes include postgraduation a c t i v i t y as an outcome
measure.(')
Information On Student
Outcome Is Limited
Despite the importance of outcome information, ASDB has collected l i t t l e
information in the past about students a f t e r they graduate. For example,
the most recent annual report ( 1989- 90) indicates that 73 percent of the
Class of 1990 are enrolled i n postsecondary educational programs.
Another 24 percent are employed or in job training programs. However,
this information i s based solely on the students' plans at time of
graduation. ASDB s t a f f do not contact students a f t e r graduation to
determine whether they accomplished t h e i r stated goals.
Although ASDB participates in a national survey of deaf school graduates,
the information collected is of limited value to the school because few
ASDB graduates respond to the survey. The highest response rate ( 19
percent) in the past f i v e years occurred in the 1990 survey; other years'
response rates ranges from 7 to 13 percent. In addition to i t s low
response rate, the survey i s limited because i t does not include
graduates of the Phoenix Day School for the Deaf, which has a larger
graduating class than the Arizona School for the Deaf. Moreover, the
School for the Blind does not conduct a systematic follow- up survey of
i t s graduates.
ASDB's limited follow- up a c t i v i t y and information about i t s graduates
appears to be typical of many state schools for the sensory impaired.
One of our consultants and others with experience in conducting post
( 1 ) The N a t i o n a l Center on Educational Outcomes i s a c o l l a b o r a t i v e e f f o r t of the N a t i o n a l
A s s o c i a t i o n o f State D i r e c t o r s o f S p e c i a l Education, the U n i v e r s i t y o f Minnesota, and
St. Cloud State U n i v e r s i t y . The C e n t e r ' s mission i s t o p r o v i d e n a t i o n a l l e a d e r s h i p i n
i d e n t i f y i n g educational outcomes f o r students w i t h d i sabi 1 i ti es and developing a
system o f i n d i c a t o r s f o r m o n i t o r i n g those outcomes.
graduation outcome evaluations suggest that few, i f any, schools
d i l i g e n t l y track graduates.
ASDB Needs To Expand
Follow- Up Of Graduates
Given the importance of outcome evaluation to judging compliance with
statutory goals and other expectations, ASDB should expand the
information i t c o l l e c t s about i t s graduates. The limited information
currently avai lable suggests that some ASDB graduates may lack the ski l Is
necessary to lead independent, s e l f - s u f f i c i e n t lives. Although ASDB has
recently i n i t i a t e d more systematic follow- up a c t i v i t i e s , additional
e f f o r t s are needed.
Available information - A l though ASDB lacks comp l ete i nformat ion about a l l
of i t s graduates, the information that i s available indicates some
graduates may not be prepared to successfully continue t h e i r education or
gain employment. As previously noted, parents and Board members
expressed concern about the low levels of achievement of ASDB graduates,
p a r t i c u l a r l y i n reading. Nationally, reading levels f o r deaf school
graduates have persisted at the t h i r d - and fourth- grade median levels f o r
two decades. One ASDB faculty member noted that such s k i l l levels are
c h a r a c t e r i s t i c of even the most i n t e l l i g e n t deaf school graduates and can
l i m i t t h e i r opportunities in college or work.
ASDB s t a f f obtain some information through contacts with vocational
r e h a b i l i t a t i o n counselors serving graduates. For example, the vocational
s t a f f at both the Tucson campus and PDSD indicated they obtain feedback
and information on individual graduates during t h e i r contacts with
vocational r e h a b i l i t a t i o n counselors. These counselors report that ASDB
graduates vary in their a b i l i t y to further their education or obtain
work. Specific problem areas noted include independent l i v i n g ,
mathematics and s p e l l i n g , reading and w r i t i n g , and a lack o f motivation
and i n t e r e s t .
Recent efforts - ASDB has recently increased i t s e f f o r t s to obtain follow
up information on students a f t e r graduation. In 1991, ASDB s t a f f
conducted a follow- up survey of the 54 ASDB- Tucson students that
graduated from 1987 through 1991. The survey found that 17 students were
employed; 20 were in postsecondary education programs; 13 were
unemployed; and 4 were out o f s t a t e and no information was available
about them. The vocational counselor at Phoenix Day School for the Deaf
was also able to provide current status information about 1990 and 1991
graduates.
The 1991 follow- up survey provides a more r e a l i s t i c description of
graduates' a c t i v i t i e s than the information routinely presented in the
ASDB annual report; however, the survey i s s t i l l too limited to serve as
a useful indicator of student outcome. The major l i m i t a t i o n of the
survey i s that i t provides very l i t t l e information about the types of
employment, wages, and quality of the graduates1 lives. Such information
would indicate whether the School is meeting the goals set by law or
student and parent expectation. Similarly, knowing only that students
are in postsecondary education programs provides l i t t l e information about
the type of programs or students' success.
ASDB s t a f f indicated they plan to expand on the survey of graduates from
1987- 1391 by following up on students three to six months after
graduation. While this e f f o r t i s a good f i r s t step, i t may s t i l l provide
only limited information because graduates may take a few years to s e t t l e
into a career or job after graduation.
I f ASDB is to adequately evaluate i t s effectiveness, the School needs to
expand i t s e f f o r t s to track students from a l l schools, campuses, and
programs. To do t h i s , s t a f f should develop a survey designed t o c o l l e c t
information about graduates' employment, education, income, and other
s i g n i f i c a n t a c t i v i t i e s over a multiyear period. The survey design should
also provide for comparing graduates' a c t i v i t i e s and achievements to the
established goal of a meaningful and productive l i f e . Such an e f f o r t
would require the School to allocate additional resources for outcome
evaluation.
RECOMMENDATIONS
1. ASDB shou l d des i gn a comp rehens i ve outcome eva l uat ion mode l based on
the School's statutory goals.
2. ASDB should designate staff to carry out the activities required by
the design. The designated staff should be given adequate time to
complete all required tasks.
3. ASDB should include the results of its outcome evaluation in its
annual report and in a report to the Legislature.
OTHER PERTINENT INFORMATION
During our audit, we collected information on ASDB teaching methods and
c u r r i c u l a as well as the School's construction program.
Teachina Methods And Curricula
As part of their review, our consultants reviewed ASDB c u r r i c u l a and
teaching methods. Although they found the c u r r i c u l a and methods to be
good, the consultants also found that some equipment i s obsolete,
especially i n the School for the Blind.
Teachinq methods and c u r r i c u l a are comnended - The consultants found
that ASDB teaching methods r e f l e c t contemporary thought and trends i n
sensory- impaired education, and report that ASDB teaching methods and
curricula at both campuses are exemplary in some areas and good i n
others. They note that ASDB's Independent Living Center provides
occupational studies and consumer education. According to the
consultants, ASDB's Transition Program, which helps student and parents
look at po. ssible postgraduation employment opportunities, is unusually
strong and managed in a creative way. The consultants state that ASDB
s t r i v e s for an up- to- date approach in i t s programs, and they agree, with
the favorable accreditation reports ASDB has received.
Consultants also commended the following special programs
@ The Re~ ional Services Proqram, which uses q u a l i f i e d local personnel
to provide services to preschool, sensory- impaired children that l i v e
i n sparsely populated areas and might otherwise not be served.
The Arizona Diaanostic Testinq and Education Center, which provides
diagnostic and educational services for multiply handicapped,
severely sensory- impaired children.
The North Central Reqional Cooperative, which provides i t i n e r a n t
services to the sensory- impaired pupi Is of 31 p a r t i c i p a t i n g school
d i s t r i c t s in Coconino, Yavapai, and parts of Mohave, Navajo, and Gila
Counties under a p i l o t program i n s t i t u t e d in 1989.
Special eauiment shorta~ es e x i s t - According to the consultants,
equipment provision i s uneven and, since the 1987 audit, some s i g n i f i c a n t
shortages have developed, i n large part as a result of midyear budget
cuts. Budget data confirm that i n f i s c a l years 1987- 88 through 1991- 92,
midyear budget cuts reduced planned equipment purchases by over 50
percent as $ 370,258 of $ 675,500 in authorizations were reverted to the
State treasury.
According to the consultants, the greatest shortage of equipment i s i n
the School for the Blind ( ASB). Advances in computer technology have,
they note, provided devices such as voice- to- type u n i t s , which can
greatly enhance the employability of visually- impaired students and help
them become i ndependen t , product i ve c i t i zens . ASB a l so needs Bra i l l e and
Speak and NoteTaker devices.
Consultants found, however, that PDSD's Center for Laboratory Studies and
i t s l i b r a r y of 10,000 computer accessible books are commendable uses of
new technology. They believe the new Learning Resource Building on the
Tucson campus w i l l f a c i l i t a t e development of a similar center there i f
budget constraints do not c u r t a i l equipment purchases.
ASDB Construction Proq- ram
A major building program at ASDB's Tucson campus, which began with
replacement of the food service bui lding ( as recommended in our 1987
a u d i t ) , w i l l be completed in December 1992 w i t h d e l i v e r y of f i v e other
new structures. The construction cost of the project is expected to
exceed $ 15.5 m i l l i o n ; however, the new buildings were acquired under 20
year l ease/ pu rchase agreements , w i t h annua l paymen t s of over $ 1 .6
m i l l i o n . ' Thus, the t o t a l cost is expected to exceed $ 33 m i l l i o n over
20 years ( see Table 3, page 59). In addition to the new construction,
two large modular buildings were bought and moved to the Tucson campus
for s l i g h t l y over $ 1 m i l l i o n .
( 1 ) Lease/ purchase payments vary from year t o year w i t h changes i n i n t e r e s t r a t e s ,
insurance c o s t s , and the o t h e r v a r i a b l e c o s t s .
TABLE 3
ESTIMATED COST OF CONSTRUCTION AND LEASE/ PURCHASE PAYMENTS
ON SIX NEW AND TWO USED MODULAR BUILDINGS
AT ASDB'S TUCSON CAMPUS
( Unaud i t ed 1
New Buildinqs
Food Service
High School
Middle School
Elementary School
Learn i ng Resources
Center
Auditorium
Unallocated Archi-t
e c t u r a l , Improvement
and Other costs( c)
SUBTOTALS
Modular Buildings
TOTALS
Estimated
Estimated Cost to State
Estimated Annua l Over Life of
Cost of Lease/ Purchase Lease/ Purchase
Construction( a) Pavment Aareements
( a) May 1, 1992 estimate of f i n a l costs f o r buildings under construction.
( b ) Final cost f o r completed b u i l d i n g .
( c ) Includes fees and costs comnon t o more than one b u i l d i n g , such as water and sewer and
other s i t e improvements.
Source: Arizona Department of Administration and ASDB Associate
Superintendent for Business and Finance.
The new construction addresses a v a r i e t y o f problems. Our 1987 audit
confirmed ASDB reports that the food service building was i n serious
d i s r e p a i r , w i t h f a u l t y beams, plumbing, and e l e c t r i c a l and f i r e control
systems, and recommended correcting a number of faults immediately and
replacing the building as soon as possible. In addition to our audit
recommendations, ASDB closed i t s auditorium due to structural problems,
determined that i t s library did not comply with Federal regulations on
handicapped access, and i d e n t i f i e d other buildings that needed major
renovations or replacement. Consequently, the Legislature approved the
construction o f f i v e new structures.
ASDB's construction budgets did not include monies to furnish and equip
the f i v e new buildings. An estimated $ 1.5 m i l l i o n w i l l be needed for
additional furnishings and equipment for these buildings.(')
Administrators expect to request about $ 400,000 per year for four years
to provide the funding necessary for furniture and equipment.
( 1 ) Some f u r n i s h i n g s and equipment already owned by the School w i l l be used i n the f i v e
new bui 1 dings .
SUNSET FACTORS
In accordance with A. R. S. $ 41- 2954, the Legislature should consider the
following 12 factors i n determining whether the Arizona School for the
Deaf and the Blind should be continued or terminated.
1. Obiective and pumse in establish in^ ASDB
The o r i g i n a l intent i n establishing the Arizona School for the Deaf
and the Blind ( ASDB) was to provide educational opportunities f o r
sensory- impaired children between the ages of 6 and 21. The 1988
Session Laws, Chapter 237 provides a further statement of purpose i n
that the School shall
. . . promote and maintain an educational opportunity of
adequate scope and q u a l i t y for sensory impaired children in
t h i s state which w i l l lead to an adult l i f e of independence
and s e l f - s u f f i c i e n c y , a meaningful personal, family and
community l i f e , and a useful productive occupational l i f e .
2. The effectiveness with which ASDB has met its obiective and purpose
and the efficiencv with which the Asencv has o~ erated
In general, ASDB appears to be e f f e c t i v e in providing educational and
other services to sensory- impaired children. Both recent
accreditation reports and our consultants found that ASDB educational
programs were of a high c a l i b e r , u t i l i z i n g modern c u r r i c u l a and
teaching methods. ASDB's building program i s replacing obsolete
structures with modern f a c i l i t i e s s p e c i f i c a l ly designed for serving
the sensory impaired. ASDB has developed and operates successful
regional programs for both preschool and school- age children.
However, the School could improve i t s e f f i c i e n c y by streamlining i t s
management structure at a savings of over $ 500,000 annually ( see
Finding I , page 7). The School could help ensure i t i s e f f e c t i v e by
increasing i t s e f f o r t s to evaluate i t s graduates' success i n
postsecondary education programs and employment ( see Finding V i , page
51).
3. The extent to which ASDB has o~ eratedw ithin the ~ u b l i cin terest
ASDB has operated within the public interest through i t s provision of
services to sensory- impaired students. ASDB provides direct
educational and other services to over 1,000 preschool through high
school- aged pupils in the State. In addition, ASDB is the only
residential school for sensory- impaired children in Arizona.
Further, ASDB also provides a variety o f resource services to school
d i s t r i c t s and administers the cooperative p i l o t program in the
northern part o f the State.
However, the public interest has not been well served by ASDB's use
of nonappropriated school funds ( see Finding 1 1 , page 19). The ASDB
Board could strengthen the School's a b i l i t y to operate within the
public interest by exercising i t s authority over School operations
and finances more e f f e c t i v e l y ( see Finding I V , page 37).
4. The extent to which rules and requlations promulaated by ASDB are
consistent with the leaislative mandate
Whether ASDB has authority to promulgate rules is unclear. Because
i t i s - not s p e c i f i c a l l y exempt from the requirements of the
Administrative Procedures Act as are other educational bodies, some
ASDB policy development may be subject to requirements and procedures
for rule making. See Sunset Factor number nine for further
discussion and recommendation.
5. The extent to which ASDB has encouraaed input from the public before
atina its rules and requlations and the extent to which it has
informed the public as to its actions and their expected impact on the
public
Again, whether ASDB has authority to promulgate some rules is
unclear. See Sunset Factor number nine for discussion and
recwrnenda t i on.
6. The extent to which ASDB has been able to investiaate and resolve
complaints that are within its iurisdiction
ASDB's enabling legislation does not establish a formal complaint
review process. Public law 94- 142 and State statutes authorize ASDB
along with the Arizona Department of Education to conduct due process
hearings to resolve any disagreements regarding student evaluation
and placement.
7. The extent to which the Attorney General or any other a~ olicable
auencv of State aovernment has the authoritv to prosecute actions
under its enablina lea- islation
ASDB's enabling legislation does not establish such authority.
8. The extent to which ASDB has addressed deficiencies in its enablina
statutes which prevent it from fulfillina its statutorv mandate
As a result o f issues detailed in our 1987 ASDB audit and the report
of a Joint Legislative Committee formed to study ASDB, a number of
statutory changes were proposed and adopted into law in 1988. These
changes increased the ASDB Board from 5 to 7 voting members; amended
the evaluation and placement process to mandate parent and local
school d i s t r i c t participation; required the Superintendent to report
annually to the Board on the use of monies received as donat

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PERFORMANCE AUDIT
ARIZONA SCHOOL FOR
THE DEAF AND THE BLIND
Report to the Arizona Legislature
By the Auditor General
October 1992
92- 4
DOUGLAS R. NORTON, CPA
AUDITOR GENERAL
STATE OF ARIZONA
OFFICE OF THE
AUDITOR GENERAL
October 13, 1992
Members of the Arizona Legislature
The Honorabie F i f e Symington, Governor
Ms. Betty Borland, Chairman
Board of Directors
Arizona School for the Deaf and the Blind
Transmitted herewith is a report of the Auditor General, A Performance
Audit of the Arizona School for the Deaf and the Blind. This report is
ir response to a December 13, 1991, resolution of the J o i n t Legislative
b* arsight Comittee.
The report addresses the need to 1) streamline the school's management
and administrative hierarchy; 2) strengthen controls over local funds and
donations; 3) improve the Board's oversight of school operations; and 4)
expand the school's role as a statewide resource to local school
d i s t r i c t s . The report also recognizes the s i g n i f i c a n t improvements made
by the school to address concerns raised in our 1987 audit.
My s t a f f and I w i l l be pleased to discuss or c l a r i f y items in the report.
This report w i l l be released to the public on October 14, 1992.
Sincerely,
~ d&& R. Norton
Auditor General
DRN : l mn
2700 NORTH CENTRAL AVENUE . SUITE 700 PHOENIX, ARIZONA 85004 ( 602) 255- 4385 . FAX ( 602) 255- 1251
SUMMARY
The Office of the Auditor General has conducted a performance audit and
Sunset Review of the Arizona School for the Deaf and the Blind, pursuant
to a December 13, 1991, resolution of the Joint Legislative Oversight
Committee. This performance audit was conducted as part of the Sunset
Review set forth in Arizona Revised Statutes ( A. R. S.) 6041- 2951 through
41- 2957. This is the second performance audit of the Arizona School for
the Deaf and the Blind conducted by the Auditor General. The f i r s t
performance audit, Auditor General Report 87- 10, was conducted in 1987.
The Arizona School for the Deaf and the Blind ( ASDB) provides
educat i ona l and other services to sensory- impai red students. The
School's Tucson and Phoenix campuses provide kindergarten through high
school classes for approximately 500 day and residential students. ASDB
also provides preschool and outreach programs for approximately 450
infant and preschool- age children; administers a regional cooperative
program in the northern part of the State to provide improved
educational programming to sensory- impaired students in their home
schools; and serves as a resource to local school d i s t r i c t s . ASDB i s
governed by a seven- member Board that appoints a Superintendent to
oversee school operations.
The School's Administrative Structure Is Top- Heavy And
Could Be Downsized To Save Over $ 500,000 Annually
( see pages 7 through 17)
We found the number of top administrators in ASDB's administrative
structure has grown s i g n i f i c a n t l y since the early 1970s, even though
enrollment at the Tucson campus has declined. Board members,
administrators, teachers, s t a f f , and parents a l l expressed concerns to us
about the School's top- heavy administrative structure. Our analysis of
the administrative structure revealed that 10 positions at the Tucson
campus and one at the Phoenix campus could be eliminated, providing f i r s t
year savings of over $ 400,000 and long- term cost savings of over $ 500,000
annually. These savings could be applied to needed ASDB programs that
have been underfunded.
The Board Should Improve Its Oversiqht And Control
Over Nonappropriated Funds ( see pages 19 through 27)
The Board has allowed school administrators too much latitude in the use
of nonapp rop r i a t ed funds. These funds , wh i ch i nc l ude dona t i ons and l oca l
funds, have in some cases been misused or imprudently used. For example,
the School spent $ 54,070 in trust and other nonappropriated funds for
out- of- state travel in fiscal year 1990- 91, much of i t for
administrators. In two instances, 11 administrators attended the same
conference. In addition, the former Superintendent violated State
purchasing statutes and may have violated c o n f l i c t o f interest statutes
in previous years when he used School funds to purchase $ 3,500 worth of
commemo rat i ve mugs. In another instance in 1989, the former
Superintendent used an estate's $ 2,000 bequest to the School for
out- of- state travel rather than depositing i t in the trust fund for
investment. Board control over nonappropriated funds i s very important
because these monies are exempt from the State budgeting process.
ASDB Has lm~ roved Student
Evaluation And Placement
( see pages 29 through 36)
Our 1987 audit reported major problems with student admission and
placement. Our current review found ASDB has corrected most of these
problems; however, some problems remain with placement of multiply
handicapped students and students with severe emotional disorders.
Programs for these students are costly, and ASDB's role in serving these
students i s unclear. The Legislature should establish a task force of
ASDB, Department of Education, local school d i s t r i c t , and Department of
Health Services o f f i c i a l s to address the needs of these students.
The Board Needs To lm~ rove Its Gc. - - 7ance
Of The Arizona School or The Dea _ , nd The Blind
( see pages 37 through 43)
Board oversight and control of School operations has been weak. Until
informed by several outside parties, the Board was unaware of significant
management and f i nanc i a l prob l ems at the Schoo l . Other ev i dence of the
Board's weak oversight includes i t s fai lure to evaluate the former
Superintendent's performance during four of the last f i v e years; develop
a comprehensive set of p o l i c i e s t o guide administrators in managing
operations and finances; and address substantive policy issues i n Board
meet ings.
Other Issues
In addition, our report contains two findings that address the following
I ssues .
ASDB needs to do more to f u l f i l l i t s mandated role as a statewide
resource to local school d i s t r i c t s . During our review, we found the
regional cooperative program to be successful, and recommend
expanding the program to two other regions. ASDB also needs to
expand other services to d i s t r i c t s , such as evaluation services,
summer programming, and providing equipment and materials. Funds
for expanded programming could be derived from the cost savings
realized by streamlining the School's top- heavy administrative
structure. ( See Finding V, pages 43 through 49.)
ASDB needs to increase i t s e f f o r t s in monitoring the success of i t s
graduates. Tracking graduate performance in the workplace or in
higher education can assist ASDB in determining whether the School's
programming is meeting i t s statutory mandate of preparing students
to lead "... an adult l i f e of independence and self- sufficiency, a
meaningful personal, family and community l i f e , and a useful
productive occupational l i f e . " ( See pages 51 through 56.)
TABLE OF CONTENTS
INTRODUCTION AM) BACKGROUND. . . . . . . . . . . . . . . . .
FINDING I: THE SCHOOL'S ADMINISTRATIVE STRUCTURE
IS TOP- HEAVY AND COUU) BE DOWNSIZED
TO SAVE OVER $ 500,000 ANNUALLY . . . . . . . . . . . . .
Administrative Structure Is Top- Heavy. . . . . . . . . .
ASDB Could Reduce The Number Of Administrative Positions . . . . . . . . . . .
Monies Spent On Administration
Could Be Better Used For Other Purposes. . . . . . . . .
Board Needs To Study
Organizational Issues. . . . . . . . . . . . . . . . . .
Recommendations. . . . . . . . . . . . . . . . . . . .
FINDING II: THE BOARD SHWLD IMPROVE ITS
OVERSIGHT AND CONTROL OVER
NONAPPROPRIATEDFUNDS. . . . . . . . . . . . . . . . . .
Board Has Not Exercised Adequate
Control Over Nonappropriated Funds . . . . . . . . . . .
Poor Judgment Exercised
By Former Administrators . . . . . . . . . . . . . . . .
Board Needs To Strengthen Controls
Over Nonappropriated Funds . . . . . . . . . . . . . . .
Recommendations. . . . . . . . . . . . . . . . . . . . .
FINDING I l l : ASDB HAS IMPROVED
STUDENT EVALUATION AND PLACEMENT . . . . . . . . . . . .
ASDB's Evaluation And Placement
Process Has Markedly Improved. . . . . . . . . . . . . .
Placement Of M u l t i p l y Handicapped Students
Continues To Generate Controversy. . . . . . . . . . . .
Recommendations. . . . . . . . . . . . . . . . . . . . .
TABLE OF CONTENTS ( Con ' t )
INDING IV: THE BOARD NEEDS TO INPROVE
ITS GOVEFWANCE OF THE ARl ZONA SCHOOL
FOR M E DEAF AH) THE BLIND . . . . . . . . . . . . . . .
Board Oversight And Control I s Weak. . . . . . . . . . .
Action To Improve Governance I s Needed . . . . . . . . .
Recommendations. . . . . . . . . . . . . . . . . . . . .
FINDING V: ASDB'S ROLE AS A STATEWIDE RESOURCE
IS NOW CLEARLY ESTABLISHED IN STATUTE;
HOWEVER, UORE NEEDS TO BE DONE TO
FULFILL THIS MANDATE . . . . . . . . . . . . . . . . . .
ASDB I s Now Required To Serve As A
Resource To Local School D i s t r i c t s . . . . . . . . . . .
P i l o t Regional Cooperative Program Has Been
Successful And Should Be Expanded. . . . . . . . . . . .
Services Provided To Local School D i s t r i c t s
Are Limited And Should Be Increased. . . . . . . . . . .
Recommendation . . . . . . . . . . . . . . . . . . . . .
FINDING VI: ASDB NEEDS TO COLLECT W E
COMPREHENSIVE INFOWITION ABWT ITS
STUDENTS' POST GRADUATION SUCCESS. . . . . . . . . . .
lnformation About Student Outcome Is
An Important Management Tool . . . . . . . . . . . . . .
lnformation On Student
Outcome I s Limited . . . . . . . . . . . . . . . . . . .
ASDB Needs To Expand
Follow- Up Of Graduates . . . . . . . . . . . . . . . . .
Recommendations. . . . . . . . . . . . . . . . . . . . .
OTHERPERTINENT INFORMATION. . . . . . . . . . . . . . . . .
SUNSET FACTORS. . . . . . . . . . . . . . . . . . . . . . . .
AGENCY RESPONSE
LlST OF TABLES
Page
TABLE 1 ARIZONA SCHOOL FOR THE DEAF AND THE BLIND
STATEMENTS OF FTEs AND ACTUAL AND
APPROVED EXPENDITURES
FISCAL YEARS 1989- 90, 1990- 91,
AND 1991- 92 ( Unaudited) . . . . . . . . . . . 3
TABLE 2 ARIZONA SCHOOL H) R M E DEAF AND THE BLIND
TRUST FIJM) AND LOCAL FUND
FTORRA VFEILS CEAXPL EYNEDAIRT UR19E9S0 B- 9Y1 PO( USnIaTuIOdiNtSe d). . . . . .
TABLE 3 ESTIMATED COST OF CONSTRUCTION AND
LEASE/ PURCHASE PAYMENTS ON SIX NEW
AND TWO USED UOWLAR BUl LDl NGS AT
ASDB'S TUCSON CAMPUS ( Unaudited) . . . . . . . 59
LlST OF CHARTS
CHART 1 ARIZONA SCHOOL FOR THE DEAF AND THE BLIND
. ADMINISTRATIVE STRUCTURE IN 1974 . . . . . . . 8
CHART 2 ARIZONA SCHOOL FOR THE DEAF AND THE BLIND
ADMINISTRATIVE STRUCTURE
IN FlSCALYEAR1991- 92. . . . . . . . . . . . . 9
CHART 3 ARIZONA SCHOOL FOR THE DEAF AND THE BLIND
PROPOSED ADMINISTRATIVE STRUCTURE. . . . . . . . 14
INTRODUCTION AND BACKGROUND
The Off ice of the Auditor General has conducted a performance audit and
Sunset Review of the Arizona School for the Deaf and the Blind, pursuant
to a December 13, 1991, resolution of the J o i n t L e g i s l a t i v e Oversight
Committee. This performance audit was conducted as part of the Sunset
Review set f o r t h in Arizona Revised Statutes ( A. R. S.) $ 941- 2951 through
41- 2957. This i s the second performance audit of the Arizona School for
the Deaf and the Blind conducted by the Auditor General, The f i r s t
performance audit, Auditor General Report 87- 10, was conducted i n 1987.
School's Purpose, Proarams, And Structure
The o r i g i n a l intent i n establishing the Arizona School for the Deaf and
the Blind ( ASDB) was to provide educational opportunities f o r
sensory- impaired students ages 6 through 21. In 1988, the Legislature
redefined ASDB's mission as follows:
The purpose of the Arizona state school for the deaf and the
b l i n d i s to promote and maintain an educational opportunity of
adequate scope and q u a l i t y for sensory impaired children i n t h i s
state which w i l l lead to an adult l i f e of independence and s e l f
s u f f i c i e n c y , a meaningful personal, family and community l i f e ,
and a useful productive occupational l i f e .
In i t s role, ASDB provides d i r e c t educational services to students and
also acts as a resource to local school d i s t r i c t s . ASDB provides d i r e c t
educational services at campuses in Phoenix and Tucson. The Phoenix Day
School for the Deaf ( PDSD) has an enrollment of approximately 200
students and provides kindergarten through twelfth- grade classes for
hearing- impaired and sensory- impaired, m u l t i p l y handicapped students that
I ive at home i n the Phoenix met ropol i tan area. The Tucson campus has an
enrollment of approximately 150 day and 160 residential students and
provides kindergarten through twelfth- grade classes for students t h a t are
hearing- impaired, visually- impaired, or m u l t i p l y handicapped with a
sensory impairment. Residential students are those that l i v e on campus
during the school year, primarily because t h e i r home school d i s t r i c t
cannot prov i de the needed educat i ona l serv i ces . The Tucson campus a l so
provides evaluation and educational services to m u l t i p l y handicapped
chi ldren with a sensory impairment through i t s Arizona Diagnostic Testing
and Educat i on Center ( ADTEC) .
ASDB also provides other services throughout the State and to local
school d i s t r i c t s . ASDB administers preschool and outreach programs for
approximately 450 infant and preschool- age children. In addition, ASDB
administers a regional cooperative program i n the northern part of the
State i n which 31 school d i s t r i c t s pool special education resources to
provide improved educational programming to sensory- impaired students i n
thei r home schools. ASDB also serves as a resource to local school
d i s t r i c t s for evaluations, c u r r i c u l a , and t r a i n i n g .
ASDB i s governed by a seven- member Board comprising the State
Superintendent for Education or his or her designee and s i x members
appointed by the Governor. The Board appoints a Superintendent to
oversee the d a i l y operations of the School.
Budaet And Personnel
ASDB's operat i ng budget cons i sts of both appropr i ated and nonappropr i ated
funds. Appropriated funds include General Fund monies, a per student
a1 location from the Department of Education's Special Education
I n s t i t u t i o n a l Voucher Fund, and charges for nonresident t u i t i o n .
Nonappropriated funds include Federal grants ($ 508,000 estimated for
f i s c a l year 1991- 921, the school's trust fund earnings, donations, and
local funds. The ASDB's trust fund consists of monies bequeathed to the
school by p r i v a t e donors, which are then invested and managed by a
contracted financial advisor. The current value of the t r u s t fund is
$ 1.6 m i l l i o n , yielding an estimated $ 92,400 in earnings for f i s c a l year
1991- 92. Local fund monies include a1 I other monies a v a i l a b l e t o the
school and are used for a v a r i e t y o f purposes. Finding 1 1 , page 19
describes ASDB's nonappropriated funds.
The Legislature authorized 477.7 f u l l - t i m e equivalent employees ( FTEs)
for ASDB for f i sca I year 1991- 92; however, ASDB employs approximately 800
people to implement i t s program r e s p o n s i b i l i t i e s . Many of these
employees are part- time. Table I, page 3 l i s t s ASDB's expenditures and
the number of FTEs for i t s appropriated funds.
2
TABLE 1
ARIZONA SCHOOL FOR THE DEAF AND THE BLIND
STATEMENTS OF FTEs AND ACTUAL AND APPROVED EXPENDITURES
FISCAL YEARS 1990- 91, 1991- 92, AND 1992- 93
( unaudited)
FTEs
Personal services
Employee related
Prof. & outside services
Travel, in- state
out- of- state( a)
Other operating
Food
Land, Buildings
and Equipment
Lump Sum reduction
TOTAL
1990- 91
Actual
1991- 92
Actual
1992- 93
ADD roved
( a ) ASDB budgets most o f i t s out- of- state t r a v e l from nonappropriated t r u s t and l o c a l fund
monies. For f i s c a l year 1990- 91, ASDB expended $ 54,070 from these funds f o r
out- of- state travel.
Source: Arizona Financial Information System reports for Fiscal Years
1990- 91, and 1991- 92; State of Arizona Appropriations Report for
Fiscal Year ending June 30, 1993.
Audit Methodolow And Scope
In addition to u t i l i z i n g standard audit methodology, such as data
analysis, records review, and interviewing, we employed other methods to
determine the efficiency and effectiveness of the School's operations and
programs. We surveyed a l l 233 local school d i s t r i c t s i n the State. We
also surveyed a stat i s t i c a l ly s i g n i f i c a n t sample of parents of chi ldren
in ASDB programs and parents of children in the regional cooperative
program. We also contracted with experts in the f i e l d of education for
the sensory- impaired to evaluate and determine whether ASDB had resolved
the problems concerning student evaluation and placement we found in our
previous audit.
Our audit report of ASDB presents findings and recommendations in six
areas :
Whether ASDB1s management structure is top- heavy and could be
downs i zed
Whether ASDB1s nonappropr i ated funds have proper oversight and
control
Improvements and continued problems with student evaluation and
p l acemen t
Adequacy of Board governance of school operations
Need for ASDB to expand i t s role as a resource to local school
d i s t r i c t s
Need for ASDB to track student postgraduate performance
In addition to these audit areas, we present a section of other pertinent
information that includes information on the adequacy of teaching methods
and equipment at the School and an overview of the scope and progress of
the School's building program ( see pages 57 through 60). In addition,
this report contains a response to the 12 Sunset Review factors ( see
pages 61 through 65).
The audit was conducted in accordance with government auditing standards.
The Auditor General and staff express appreciation to the President of
the Board of Directors, Board members, and the management and staff of
the Arizona School for the Deaf and the Blind for their cooperation and
assistance throughout the audit.
FINDING I
THE SCHOOL'S ADMINISTRATIVE STRUCTURE IS TOP- HEAVY
AND COULD BE DOWNSIZED TO SAVE
OVER $ 500,000 ANNUALLY
ASDB's administrative structure has an excessive number of top
administrators, and some positions could be eliminated so that monies
could be better spent on direct services to students. In addition, the
Board should study some other organizational and position- related issues.
Administrative Structure
Is T o p H e a w
Despite a decline in enrollment at the Tucson campus, ASDB's
administrative structure has grown significantly since the early 1970s.
Board members, administrators, staff, and parents have expressed concerns
about ASDB's top- heavy administrative structure. As a result of these
concerns, we examined the administrative structure to determine whether
various positions were needed.
Growth of the administrative structure - The number of ASDB
administrators has increased since the early 1970s, particularly at the
Tucson Campus. However, during the same period, the Tucson campus
enrollment has decreased approximately 25 percent, from 418 students in
1974 to 310 in January 1992. In 1974, the administrative structure was
fairly simple and streamlined. Since 1974, the structure has grown in
both numbers of administrators and layers of administration. For
instance, the creation of several director- level positions added a layer
to the management structure and additional directors have been added over
the years.(') Charts 1 and 2 ( pages 8 and 9) illustrate the increase by
comparing ASDB's administrative structure in 1974 with the current
structure.
( 1 ) Two off- campus programs have been added since 1974. The Regional Services Program
serves 450 sensory impaired i n f a n t s and preschool c h i l d r e n throughout t h e S t a t e . The
Regional Cooperative Program p r o v i d e s e d u c a t i o n a l o p p o r t u n i t i e s t o sensory impaired
students i n t h e i r home school d i s t r i c t s . Our a n a l y s i s , however, focused p r i m a r i l y on
the Tucson campus a d m i n i s t r a t i v e s t r u c t u r e .
ARIZONA SCHOOL MR THE DEAF AH) THE f3LlhD
ADMINISTRATIVE STRUCTURE
IN 1974
SUPER1 NTENDENT n
SUPERINTENDENT
1 V1ocAT- xonA1L ~ 1VOC ATIONAL wPTE~ AlC! H" EsRx w
EDUCATION EDUCATION ( a)
- - 7
SUPERVISING
ELEMENTARY
SUPERVI S I f f i
TEACHER
SUPERVISOR
HOUSEKEEPING
( a ) This i s one position which serves both the deaf and blind schools.
SUPERVISOR
BUILDINGS 6
GROUNDS
FOOD SERVICE F\ Fl
BUSINESS
MANAGER
PRI NClPAL PRINCIPAL DIRECTOR DIRECTOR
DEAF SCHOOL BLIND SCHOOL STUDENT PHOENIX DAY
LIVING SCHOOL
+ 1 # ; I
I I I I
SPECIAL
PROGRAMS
DIRECTOR
i -
CHART 2
ARI U) NA SCHOOL FOfl THE DEAF AND THE BL lND
MYINiSTRATiVE STflEWE
IN FISCAL YEAR 1991- 92
ASSOCIATE - I W P E R l Y I E * D E * I
I DUS 1 F I N I ASSOCIATE
SWERlMlE*) EMl
CUI L IYS1R I
DAY YYODL 1YE . LI* D StRVICES 1111 DEAF
I
I Dssy 1 I D I R E C l m YLUGER
C W T f R A I I V E
SERVICES OWUS US W l M l E U K f SERVICES
SERVICE
r 0 5 0 c w s I
H SERVICE SPEC Y Y E R V I YIII
MEDIA L Ml* I
Widespread concern about towheavv administration - Board members,
administrators, s t a f f , and parents have expressed concerns about the
number of top administrators and middle managers at ASDB. The perception
that the administration i s top- heavy i s shared among these groups, as
summarized below.
Four Board members indicated to us that the administration is
top- heavy and one suggested that monies spent on administration could
be used to provide direct services to students. In fact, the Board
has discussed this issue at i t s meetings and plans to study the
organizational structure to address these concerns.
Administrators and s t a f f members view the administration as being
top- heavy. Teachers and residential s t a f f have suggested that the
top administration be reorganized and that administrative secretarial
s t a f f be cut to reduce positions. In addition, several
administrators and s t a f f pointed out particular positions that they
consider unnecessary. Some s t a f f members were also concerned that
during a reduction in force ( RIF) budget cut last year, although
direct service positions were cut, management positions were not
reduced.
Parents also indicated that the number of administrative positions
should be reduced. During deliberations about last year's RIF
parents suggested cutting administrators rather than direct service
functions for students.
ASDB Could Reduce The
Number Of Administrative Positions
The Board should downsize ASDB's administrative structure. We found that
ASDB could eliminate 11(') administrative positions.(') The
organizational structure resulting from these reductions would allow
adequate coverage of the du t i es and func t i ons necessary to manage the
Schoo I .
Administrative positions could be eliminated - During our audit we
i d e n t i f i e d the following 11 positions that could be eliminated from upper
( 1 ) These 11 p o s i t i o n s include two part- time p o s i t i o n s and equate t o a t o t a l of 10 FIE
p o s i t i o n s .
( 2 ) Our examination consisted of reviewing job d e s c r i p t i o n s , determining spans of c o n t r o l ,
comparing ASDB's s t r u c t u r e w i t h other state schools, reviewing previous ASDB proposals
f o r s t a f f reduction, comparing the current s t r u c t u r e w i t h ASDB's past s t r u c t u r e s , and
i n t e r v i e w i n g numerous management and s t a f f members. I n a d d i t i o n , our consultants were
asked to comnent on the organizational s t r u c t u r e . Management p o s i t i o n s were
considered f o r e l i m i n a t i o n i f we determined that the duties and functions of one
administrative p o s i t i o n could be s u f f i c i e n t l y covered by another p o s i t i o n .
and middle management, which would eventually save over $ 500,000
annually(') in salaries and benefits.
The Associate Suoerintendent for Curriculum and I n s t r u c t i o n position
($ 74,000) is unnecessary. The Associate Superintendent i s
responsible for the oversight of the academic programs. However,
this position was vacant from August 1991 to July 1992 while the
Associate Superintendent served as Acting Superintendent. The
Directors operate the programs on a day- to- day basis and could report
d i r e c t l y to the Superintendent. In addition, a study found that few
other states operate schools for the deaf and the blind with an
Associate Superintendent.
The Assistant F a c i l i t i e s Mana~ er position ($ 42,000) on the Tucson
Campus is not a full- time supervisory position; rather, the Assistant
F a c i l i t i e s Manager assumes the responsibility of F a c i l i t i e s Manager
in his absence and performs carpentry work. Currently, the
F a c i l i t i e s Manager is coordinating the building program and i s often
busy with construction- related items. The end of the building
program this December w i l l allow the F a c i l i t i e s Manager to resume the
day- to- day supervision of personnel and routine maintenance matters.
Therefore, the Assistant F a c i l i t i e s Manager position w i l l not be
necessary.
The Hiah School P r i n c i ~ a l in the School for the Deaf position
($ 62,000) is unnecessary and could be eliminated by combining the
middle school and high school programs. The School for the Deaf in
Tucson currently has three Principals to serve 186 students, while
the Phoenix Day School for the Deaf ( PDSD) operates with only two
Principals for 209 students. In addition, the High School Principal
in the School for the Deaf has the smallest span of control of a l l
the Principals in the academic departments, supervising only seven
teachers. By contrast, the PDSD Principals supervise an average of
( 1) A l l p o s i t i o n costs shown i n parentheses were determined u s i n g t h e s a l a r y and b e n e f i t s
of the person c u r r e n t l y holding the p o s i t i o n . Salary amounts have been rounded to the
nearest thousand d o l l a r s . I n c o r p o r a t i on of ASDB's " bumping" p o l i c y would, however,
reduce the immediate d o l l a r savings. The pol i c y provides permanent employees, whose
p o s i t i o n s are eliminated, w i t h c e r t a i n " bumping r i g h t s " t o other ASDB p o s i t i o n s f o r
which they may q u a l i f y . An i n d i v i d u a l who bumps i n t o a lower c l a s s i f i c a t i o n i s placed
a t the step i n that c l a s s i f i c a t i o n closest to t h e i r c u r r e n t s a l a r y . Since the
i n d i v i d u a l s they are bumping have the l e a s t s e n i o r i t y i n the c l a s s i f i c a t i o n , i t i s
common t h a t the i n d i v i d u a l bumping i n t o that c l a s s i f i c a t i o n ( from a higher p o s i t i o n i n
the agency hierarchy) w i l l earn more than the i n d i v i d u a l they are bumping. The
immediate net savings i n the R I F process i s the s a l a r y / b e n e f i t s of the employee
a c t u a l l y bumped from the agency plus or minus any costs/ savings that accrue through
the bumping chain of events. However, given turnover, promotions, e t c . , over time the
f u l l savings from e l i m i n a t i n g a p o s i t i o n are r e a l i z e d .
ASDB estimates the immediate savings to be approximately $ 413,000 annually f o r the
positions i d e n t i f i e d i n t h i s f i n d i n g .
19 teachers plus instructional aides. Our consultants recommend that
the Deaf High School and Middle School be combined to enhance the
program for students in both departments. They stated that two
Principals were not necessary to run the middle school and high
schoo l programs.
We contacted three schools in other states regarding t h e i r programs
and found that the South Carolina School for the Deaf and Blind,
which i s similar in size to ASDB, has only two assistant principals.
Also, the Arkansas School for the Deaf, which is comparable to the
Deaf School i n Tucson, eliminated two of their principals, and the
superintendent indicated that she has not received any complaints
from s t a f f concerning t h i s change.
One Dean position in the School for the Deaf ($ 46,000) could be
eliminated by combining the elementary and advanced residential
programs under the direction of one Dean. The Deans head the
residential programs and supervise the Teaching Parents and Night
Supervisors that instruct and supervise pupils after school. In
1974, two Deans administered three residential programs serving over
246 students. Today, four Deans serve only 160 students and provide
l i t t l e direct supervision because they work day hours while t h e i r
subordinates work evening hours. Any additional s t a f f supervision
that may be necessary could be provided by the Master Teaching
Parents, who are the experienced residential s t a f f . Because the job
descriptions for Master Teaching Parents provide for them to assume
the supervisory responsibility for residential s t a f f , direct support
to residential s t a f f should not suffer.
The Re~ ional Cooperative Proaram Di rector posi t ion ($ 72,000) is
unnecessary. Currently, the one Regional Cooperative is administered
by a Regional Supervisor in Flagstaff and a ful I- time Director based
in Tucson. Two administrators are unnecessary for t h i s program,
because North Central Regional Cooperative is managed by the Regional
Supervisor on a day- to- day basis. Further, even as additional
regions are developed, oversight of the program could be provided by
the Regional Services Program, which already provides services on a
statewide basis.
The ADTEC Director position ($ 75,000) could be eliminated by placing
the evaluation and education functions in other departments since
these evaluation and education functions w i l l be physically separated
upon completion of the new buildings next f a l l . The ADTEC evaluation
functions w i l l share the same f a c i l i t y with the Department of
Instructional Support Service's ( DISS) evaluation functions.
Therefore, the ADTEC and DlSS evaluation functions could be combined
in an agencywide resource in one department. Additionally, the ADTEC
education component could be administered by the Director of the
Blind School. The Principal of ADTEC would report to that Director.
This organization has been successfully implemented at the Florida
School for the Deaf and Blind.
PDSD Assistant Director posit ion ($ 66,000) i s unnecessary and could
be eliminated. The current role of the PDSD Assistant Director i s to
oversee the educational programs while the Director handles the
business operations of the school. However, because direct
supervisory responsibility for the business and finance operations
was sh i f ted to managers on the Tucson Campus i n 1989, two superv i sors
are unnecessary. Therefore, the Director could assume responsibility
for the educational programs, and the Tucson Campus Business and
Finance Supervisors could manage the business operations, which would
eliminate the need for the Assistant Director. This would bring PDSD
in line with other ASDB academic programs by c u t t i n g t o only two
layers of administration, instead of the current three layers: the
Director, Assistant Director, and Principals.
Four Administrative Secretarv ~ o st iio ns(') ($ 70,000) that support
the Associate Superintendent of Curriculum and Instruction ( 1 FTE),
the ADTEC program ( 1.5 FTE), and the Regional Cooperative Program
Director (. 5 FTE) w i l l not be necessary when the administrative
structure is reorganized.
Pro~ osed reoraanization would ~ r o v i d e for adeauate mana~ ement of Am -
As previously noted, the revised organizational structure would provide
s u f f i c i e n t management personnel to e f f e c t i v e l y perform the duties of the
eliminated positions. The structure that would result from eliminating
these 11 positions is shown in Chart 3, page 14. The reorganized
structure would reduce the layers of top administration from four to
three and also reduce the number of Director- level positions from seven
to f i v e .
The Board has expressed the desire to evaluate and possibly propose an
alternative restructuring that would capture similar dollar savings. The
Board has set aside funds to perform a management study. In addition,
the Board noted that the recently hired new superintendent should have
some f l e x i b i l i t y in organizing his administration. The Board's concept
has merit. Our review and recommendations are based on the school's
existing administrative structure. However, any reorganization based on
a different structure should s t i l l be expected to identify comparable or
greater administrative savings.
( 1 ) These f o u r p o s i t i o n s c o n s i s t of three FTEs
ARIZONA SCHOOL H) F1 THE DEAF AH) VHE BLIND
PROPOSED AOUINISTRATIVE STRUCTllRE
1 I I ? ERSO*( NL
DIRECTOR
Ir" ut B L I" I D I I @ SERVICE
f U L R V I W
EVALUAIIQI
SERVICE
L 1 - 1 I* I
B L I I D XnOOk 191EC lEOIOUL COOT
SERVICE Wf C
Monies Spent On Administration
Could Be Better Used For Other Purooses
The monies spent on the administrative salaries could be better used for
direct services to students if the 11 administrative positiotas were
eliminated. For example, part of the $ 500,000 annual savings could be
used to fund expansion of the Regional Cooperative Program.
Reaional Coo~ erative Proaram exDansion would require $ 291,300 - The
monies saved from reducing the administrative structure could be used
to fund two additional regional cooperative programs. Expanding the
program to two additional regions would cost an estimated
$ 291,300('), This expansion would meet the statutory mandate for
three regional cooperatives and would serve children in their home
districts in the least restrictive environment. Although ASDB has
consistently included funding for these regions in their budget
request since fiscal year 1989- 90, these regions have not been
funded. ( See Finding V, page 43 for further discussion of the need
to expand the regional cooperative program.)
In addition to expanding the Regional Cooperative Program, the savings
could be used to help fund other needed programs. Several of the needed
programs are described below.
New educational Droarams and eauiwent - The saving could also be
used to help fund a program to serve severely emotionally disturbed
students ( see Finding I l l , page 29). In addition, specialized
education equipment could be purchased for the use of new as we1 l as
present programs. In recent years, the special education equipment
budget has been cut severely; consequently, there is a great need for
this type of equipment. For example, the entire 1990- 91 budget for
specialized education equipment was eliminated due to mid- year budget
cuts. ( See Other Pertinent Information, page 57.)
Phvsical facilities imorovements - According to ASDB's capital budget
request for fiscal year 1992- 93, the School's physical facilities
need improvements, such as ai r condi t ioning in the gym and one
dormitory, alarm system upgrades, iocker room repairs, handicapped
access to rest rooms, and furnishings for the new high school
building. Also, the fire alarm systems in the gym and four residence
halls are inadequate and in violation of the State fire code.
I,
( 1) Estimate obtained from the 1992- 93 ASDB Operating Budget Request.
Expanded resource services for local school d i s t r i c t s - ASDB is
required by statute to be a resource to local school d i s t r i c t s , and
the savings from reducing the administrative structure could be used
by ASDB to comply with this mandate. According to ASDB o f f i c i a l s ,
few services are currently being provided to local school d i s t r i c t s
due to funding limitations. ( See Finding V, page 43 for further
discussion of the need for expanded resource services.)
EDP supwrt - Based on our review, the EDP function appears to be
understaffed, and more EDP support seems to be needed. Only one FTE
position i s currently allocated for EDP functions, which consists of
two half- time positions, the Grants/ Compliance/ EDP Coordinator and
the Systems Operator/ Videographer. The EDP system does not contain
basic information such as complete enrollment and student records.
In addition, the Manager i d e n t i f i e d many programming and other
projects that are needed to improve the efficiency and effectiveness
of the data processing system.
Board Needs To Study
Oraanizational Issues
The Board needs to study other issues related to the organization of
ASDB, including the evaluation of positions affected by the downsizing,
and the role of PDSD administrators in business and finance operations.
The Board determined that a management study of ASDB is needed and
allocated monies in fiscal year 1991- 92 for the study. However, they
decided to postpone the study u n t i l they receive the results o f t h i s
audit. Based on our review, the Board should conduct further study in
two key areas:
Effects of downsizinq on positions should be studied - The Board's
study should include an evaluation of the s t a f f whose duties or
responsibilities change as a result of restructuring to consider
salary adjustments. For example, the Master Teaching Parent position
would be expanded upon elimination of one Dean, and a salary
adjustment for the new responsibilities could be necessary.
Role and r e s w n s i b i l i t ~ for business functions at PDSD needs to be
c l a r i f i e d - The Board needs to c l a r i f y the role of PDSD and Tucson
Campus administrators in the operation of the Food Service,
Transportation, Accounting, and F a c i l i t i e s functions at PDSD. The
managers of these operat ions are based on the Tucson Campus and are
charged with the responsibility for these functions at both the
Tucson and PDSD Campuses. However, i t seems the Di rector of PDSD is
managing these operations. For example, the control of some
financial matters lies with the Director, and the Tucson Campus
Manager has l i t t l e knowledge of the use of some monies. As a result,
some problems with the financial transactions at PDSD have been
identified, as discussed in Finding 1 1 , page 19.
RECOMMENDATIONS
1.. The Legislature should consider reallocating appropriations for the
following 11 positions or other administrative positions i d e n t i f i e d
by the Board to the regional cooperative programs and other direct
student service programs:
Associate Superintendent of Curriculum and Instruction
Assistant F a c i l i t i e s Manager
High School Principal in the School for the Deaf
One- Dean in the School for the Deaf
Regional Cooperative Program Director
ADTEC Director
Four Administrative Secretaries
Assistant Director of PDSD
2. The Board should cost out needed programs and establish p r i o r i t i e s
for using the monies saved to provide programs for direct services to
students. The Board should then propose these alternatives to the
Legislature for their consideration.
3. The Board should conduct further studies of the positions affected by
downsizing and the role of PDSD administrators in business and
finance operations.
FINDING II
THE BOARD SHOULD IMPROVE ITS OVERSIGHT AND CONTROL
OVER NONAPPROPRIATED FUNDS
The Board should exercise greater control over the use of non-appropriated
funds. In the past, poor judgment by ASDB administrators
has resulted in State law and p o l i c y v i o l a t i o n s , excessive out- of- state
travel expenditures, and improper use of donations and other monies. To
correct these conditions, the Board should strengthen i t s oversight and
control of nonappropriated funds.
Board Has Not Exercised Adequate
Control Over N o n a ~ ~ r o ~ r i a tFeundd s
The Board has not used i t s authority to properly control nonappropriated
funds. The Board is s t a t u t o r i l y responsible for a l l monies received by
the School, including those that are not appropriated by the
Legislature. ASDB has several sources of nonappropriated funds,
including the trust fund, trust fund earnings, private donations to ASDB,
and local f- und monies.(') Income from these sources, which is described
below, exceeds $ 100,000 per year.
Trust fund and earninas - The trust fund consists of monies and other
assets bequeathed to ASDB. These monies, total ing approximately $ 1.6
m i l l i o n , are managed by the Board through an investment
counselor.( 2) The fund is expected to earn $ 92,400 in 1991- 92. In
1990- 91, trust fund earnings totaled approximately $ 88,600, of which
a l mos t $ 86,700 was expended.
Donations - ASDB receives donations in varying amounts from private
parties throughout the year. The ASDB Tucson Campus received
approximately $ 18,400 in donations and PDSD received approximately
$ 4,600 in fiscal year 1990- 91. Over the last four years, ASDB Tucson
has received an average of over $ 20,000 annual l y i n donat ions.
( 1 ) ASDB a l s o receives Federal g r a n t s . The f i s c a l year 1991- 92 budget i n c l u d e s an
estimated $ 508,000 i n Federal funds. Use o f these Federal monies was n o t reviewed as
p a r t o f t h i s a u d i t .
( 2 ) The investment p o r t f o l i o market value was $ 1,649,423 on March 31, 1992.
Local funds - Local fund monies are raised by ASDB a c t i v i t i e s and
expended for a wide v a r i e t y o f items. For example, a local fund was
established for the receipts of the sale of curriculum materials.
Board lacks control of donations and local fund monies - A1 though the
Board has improved the control over t r u s t funds, the Board allows
administrators too much discretion i n the use of donations and local
funds. The Board does not have knowledge of the donations received or
the ASDB administration's intended use of these funds. When donors do
not specify a purpose for the g i f t , administrators have been free to
deposit the monies i n any local or t r u s t fund earnings account without
informing the Board.
The Superintendent can a l s o e s t a b l i s h local funds and deposit monies i n t o
these funds. In addition, an authorized administrator can expend the
local fund monies without the knowledge or approval of the Board. The
Board generally does not receive any information regarding local funds.
Lack of oversight for nonappropriated funds was also an issue during our
1987 audit. In 1988, the Legislature amended ASDB's l e g i s l a t i o n to
require the Superintendent to report to the Board on the use of these
funds. In response the Board has tightened controls over t r u s t fund
expenditures by requiring that the t r u s t fund be budgeted in greater
d e t a i l , l i m i t i n g transfers between budget categories to less than 10
percent without Board approval, and requiring that a l l out- of- state
travel to be pre- approved by the Board. However, our current audit work
indicates that the Board s t i l l lacks information about donations and
local funds and has not adequately controlled t h e i r use.
Poor Judament Exercised
By Forme Administrators
Former administrators at ASDB have used poor judgment in handling t r u s t
fund earnings, donations, and local fund monies. In two cases,
administrators violated State laws and p o l i c i e s . More commonly, t r u s t
fund earnings and local fund monies have been used by administrators for
excessive out- of- state t r a v e l . In addition, some donations received by
the School have been poorly managed by former administrators, and local
fund monies have lacked oversight.
State laws and policies violated - We i d e n t i f i e d two instances in which
ASDB former administrators violated State laws or policies.
Exam~ le 1 - In the summer of 1986, the then ASDB Superintendent
ordered approximately 3,000 coffee mugs intended to help commemorate
the 75th anniversary of the School. The mugs were purchased at a
price of $ 2.55 each for a total procurement of approximately $ 8,700.
After the order was placed but before i t was delivered, ASDB business
o f f i c e personnel informed the Superintendent that he had violated the
State Procurement Code by f a i l i n g to seek competitive bids for the
procurement of the mugs. In response, the Superintendent contacted
the ASDB Alumni Association ( which consisted primari ly of ASDB
graduates employed at the School) and requested that they purchase
the mugs from the vendor and then s e l l them at a higher price as a
means of raising funds. However, since the Alumni Association only
had approximately $ 2,000, the Superintendent personally borrowed
$ 6,700 from a t h i r d party and loaned i t to the Association to pay the
balance of the amount due. The Association agreed to repay the
Superintendent from the proceeds of the mug sales.
Over the next several months, the Alumni Association sold the mugs
for $ 5 to $ 6 each to various groups, including sources within the
School. In t o t a l , more than $ 3,500 of ASDB funds were expended on
the purchase of mugs from the Alumni Association: $ 1,500 of trust
fund earnings, $ 1,370 of local funds, and $ 648 of general funds.
Over $ 2,000 of these expenditures were speci f ical ly approved by the
Superintendent, and records indicate that the Superintendent received
$ 5,610 back from the Alumni Association.
Comnents - Several statutory violations occurred as a result of the
mug purchase and sales. F i r s t , while acting on behalf of the School,
the former Superintendent clearly violated the procurement code when
placing the order for the mugs without obtaining competitive bids.
Second, purchases of the mugs by school o f f i c i a l s from the Alumni
Association were also v i o l a t i o n s o f the State Procurement Code,
because competitive bids were not obtained and public funds were
used. Third, in an e f f o r t to evade the i n i t i a l v i o l a t i o n o f the
Procurement Code, the former Superintendent may have also violated
the State c o n f l i c t of interest statutes when he authorized the
expenditure of ASDB funds to purchase mugs from the Alumni
Association after he loaned money to the Association and therefore
had a substantial interest in the loan being paid.
Exam~ le 2 - On July 26, 1991, PDSD signed a rental agreement with the
Arizona College of the Bible, a private concern, for the use of the
PDSD Sportsdome. The agreement allowed the college to use the gym
for i t s 1991- 92 basketball and volleybal I schedules totaling 47
games. For the rental, PDSD charged the college $ 1,400 which the
college paid PDSD in two instal lrnents of $ 700 in August 1991 and
January 1992. These monies were deposited in the PDSD local fund.
Ccnmtents - The gym at PDSD is fully funded for normal operating costs
for the year in the budget of the general fund. According to the
Department of Administration ( DOA) Finance Department, the proceeds
from the rental of the facility should be accounted for in the
general fund as a miscellaneous revenue. ( In addition, our legal
counsel believes that the monies should be reported by the
Superintendent to the Board and included in the Board's report to the
Legislature.) However, the Director deposited the rental monies in
the private fund for athletics and theatre. The Director should have
been particularly aware that this violated State pol icy, as ASDB had
unsuccessfuIly sought legislation in fiscal year 1990- 91 to obtain
authorization to deposit rental revenue in student activities
accounts .
Out- of- state travel expenditures excessive - ASDB used nonappropriated
monies for an excessive amount of out- of- state travel. In fiscal year
1990- 91, $ 49,257 ( approximately 57 percent) of the trust fund earnings
were expended for out- of- state travel. Another $ 4,813 was expended for
travel from other local funds in that fiscal year. One- half of the
monies ( 52 percent) was spent for travel for administrators. il) See
Table 2, page 23 for a summary of 1990- 91 out- of- state travel. In some
cases, travel costs were excessive. For example,
Eleven administrators attended the Conference of Educational
Administrators Serving the Deaf ( CEASD) Annual Convention in New
Orleans in June 1991, at a cost of $ 8,972.
Seven teen ASDB staff at tended the 1989 CEASD Annual Convent ion at ' the
Princess Resort in San Diego. Eleven administrators and six staff
attended. Teachers were limited to $ 200 each for the trip. However,
ASDB ful iy funded the cost of the trip for the administrators, at a
cost of up to $ 870 per administrator. The total cost of the trip was
approximately $ 9,800, almost one- thi rd of the total travel
expenditures for the year. The Board approved this trip after the
expenditures were made.
i 1 ) Despite excessive o u t - o f - s t a t e t r a v e l e x p e n d i t u r e s , few t r a v e l funds are a v a i l a b l e f o r
teaching s t a f f . I n f i s c a l year 1990- 91, teaching s t a f f t r a v e l expenditures accounted
f o r only _ percent o f t o t a l t r a v e l expenditures, as shown i n Table 2, page 23. Board
pol i c y h e a v i l y r e s t r i c t s teaching s t a f f t r a v e l , as reimbursement f o r out- of- state
t r a v e l i s l i m i t e d t o $ 200 per t r i p w i t h the remainder o f the costs p a i d by the
teachers. However, the s e c r e t a r i a l s t a f f have been f u l l y reimbursed f o r o u t - o f - s t a t e
t r a v e l . For example, an a d m i n i s t r a t i v e s e c r e t a r y and a r e c e p t i o n i s t t r a v e l e d t o
Denver i n 1990 t o a t t e n d a conference a t a cost o f $ 1,904, which was f u l l y
reimbursed. I n c o n t r a s t , a teacher p a i d a l l the c o s t s o v e r $ 200 from her own pocket
t o a t t e n d a conference i n Washington D . C . , although the ASDB p r i n c i p a l a t t e n d i n g the
same conference was reimbursed $ 1,062 f o r the t r i p .
TABLE 2
Posit ion
ARIZONA SCHOOL FOR THE DEAF AND THE BLIND
TRUST FUND AND LOCAL FUND
TRAVEL EXPENDITURES BY POSITIONS
FOR FISCAL YEAR 1990- 91
( Unaud i t ed 1
Superintendent
Associate Superintendents
Di rectors
Assistant Directors
Principals
Administrative Staff
Other Professional and
Supervisory Personnel
Teaching Staff
Basketbal I ~ ournarnent(~)
Total
Percentage of
Trips Travel T rave l
Taken Expenditures Expenditures
( a) Basketball Tournament expenditures consist o f a i r f a r e f o r students and coaches and
reimbursement of meals f o r coaches.
Sou rce : ASDB financial records for fiscal year ended June 30, 1991.
The Board i s often unaware of such expenditures u n t i l a f t e r the fact, i f
at a l l . Board approval for the two t r i p s described above was not
obtained u n t i l a f t e r the travel expenses had been incurred. In another
case two PDSD s t a f f attended a conference at a cost of $ 1,750. The
School used local funds for t h i s t r a v e l , which was never approved by the
Board.
Some donations and local funds are ~ o o rmla~ na aed - Other problems exist
i n the management of donat ions and l oca l funds . The Super i n t enden t and
the Director of PDSD receive donations for t h e i r respective campuses. I f
not r e s t r i c t e d to a s p e c i f i c purpose by the donor, these administrators
allocate donations however they choose. This s i t u a t i o n has led to
questionable management of some donations by administrators as indicated
by the following examples.
The former Superintendent received a donation of $ 2,500 i n May 1990
that the donor designated for the work subsidy fund, a fund that
provides employment for students. The Superintendent diverted $ 1,000
of t h i s donation into the account he used to pay for community- based
events to promote the School's image. However, the Superintendent
does not have the authority to change the designated purpose of a
donation and i s legally responsible i f the donation i s used for a
purpose other than the one designated. Further, the donor or the
intended b e n e f i c i a r i e s o f the donation could enforce a claim against
the Superintendent or ASDB that the donation was used inappropriately.
In August 1989, ASDB received a bequest of $ 2,000 from an estate
d i s t r i b u t i o n . H i s t o r i c a l l y , bequests received by ASDB are deposited
into the t r u s t fund and invested. However, the former Superintendent
chose to spend t h i s bequest for out- of- state travel during t h a t year.
Administrators have also established and u t i l i z e d local funds without
oversight. The following are examples of two local funds with various
problems.
Curriculum materials fund - This fund was established to receive the
proceeds from the sale o f c u r r i c u l a developed by ASDB and sold to
other schools. The monies deposited in the fund were intended to be
used to pay for the cost o f d u p l i c a t i n g and d i s t r i b u t i n g c u r r i c u l a .
Although ASDB administrators u t i l ized these monies for a variety of
curriculum- related purposes, including out- of- state travel and
purchases of computer e uipment, they did so without the knowledge or
approval of the Board. ( 19
PDSD local funds - PDSD has several local funds with revenues from a
variety o f sources, including donations and receipts from school
a t h l e t i c events. These funds were established by the PDSD Director
who, in practice, has also exercised sole control over them without
any direction from the ASDB Superintendent or the Board. These funds
have been used for out- of- state travel for the PDSD Director and
other PDSD s t a f f and for purchases o f capital equipment without the
knowledge or approval of the Board.
Board Needs To Strenclthen
Controls Over Nonappropriated Funds
The Board should strengthen controls over nonappropriated funds.
Although the Board has established a policy that requires advance
approval of travel, i t should also i n s t i t u t e further controls over the
nonappropriated funds. As an alternative, the Legislature may wish to
consider making these monies subject to appropriation.
Board has established policy to reauire advance approval of travel - In
response to concerns about excess i ve travel , the Board changed i ts pol icy
to require approval of out- of- state travel in advance and on a
trip- by- trip basis. Until recently, the former Superintendent
apportioned the lump sum budgeted by the Board for out- of- state travel in
any way he chose. After the Board learned of plans for three
administrators and three teachers to attend a conference in Hawaii in
1991, they rejected the plans for the t r i p for the administrators. The
Board f e l t the t r i p to Hawaii for administrators was inappropriate at a
time of s t a f f layoffs. Prior to this event, the Board t y p i c a l l y approved
( 1 ) I n a d d i t i o n , ASDB's p r a c t i c e of depositing the proceeds of curriculum sales i n t o i t s
curricuium materiai s tund may be inconsistent w i t h State accounting procedures.
School curriculum development s t a f f are funded through General Fund appropriations. A
Department of Administration- Finance o f f i c i a l advi sed us t h a t monies generated from
a c t i v i t i e s funded by the General Fund should be deposited i n the General Fund.
out- of- state travel after i t occurred. Since then, the Board has
requi red administrators to seek approval from the Board before travel ing
out- of- state.
Other controls over nona~ propriated funds are inadeauate - Board policies
and controls over local funds and donations are deficient in several
additional areas.
The Board does not adequately review donations when they are received
to determine their most appropriate use or review how donations are
used. Although reviewing a l l donations upon receipt i s not practical
because most are small, the Board should review large donations ( over
$ 1,000) when they are received. The Board should also review the use
of a l l donations on a quarterly basis.
The Board does not approve the establ ishment of each fund or speci fy
the expenditures that can be made from the fund. Therefore, because
the Board does not control the transactions in a particular fund, i t
may not be aware of certain transactions.
The Board does not periodical ly review and approve the revenues and
expenditures of a l l nonappropriated funds quarterly, although i t is
s t a t u t o r i l y responsible for reporting a l l financial transactions of
the School to the Governor.
Appropriation of monies may be considered - I f the Board does not
establish meaningful oversight over donations and local fund monies, the
Legislature may wish to consider including them for appropriation in the
budget, since the expenditures made from these funds include out- of- state
travel and equipment purchases. A Senate b i l l was introduced in the most
recent l e g i s l a t i v e session that would have made donations subject to
appropriation by the Legislature, however, i t did not pass.
Appropriation of the trust fund earnings and local funds would enable
greater control over the use of these monies. For example, ASDB
out- of- state travel expenditures could be more closely monitored by the
Legislature, as is done with the travel expenditures of most other State
agenc i es .
RECOMMENDATIONS
1. The Board should establish s t r i c t policies and controls over the
expenditure of nonappropriated monies. The Board should also
a. Revise ASDB's travel policy to l i m i t the number of persons on
each t r i p , increase the travel allowance for teaching s t a f f , and
require j u s t i f i c a t i o n for each t r i p .
b. Approve use of donations over $ 1,000.
c. Review the use of donations under $ 1,000.
d. Approve the estabiisnment of local fund accounts, including
specifying the sources and uses of these monies.
e. Review and approve revenue and expenditure transactions
quarterly for a funds.
2. I f the Board cannot e f f e c t i v e l y oversee or control the use of the
donations and local fund monies, the Legislature may wish to consider
appropriating them.
FINDING Ill
ASDB HAS IMPROMD
STUDENT EVALUATION AND PLACEMENT
ASDB has done much since 1987 to improve the evaluation and placement of
students at ASDB. However, some problems i n placing m u l t i p l y handicapped
students remain to be addressed.
As part of our review of ASDB's student evaluation and placement process,
we surveyed local school d i s t r i c t o f f i c i a l s throughout the State and
parents of ASDB students. We also contracted with a team of experts in
the f i e l d of sensory- impaired education t o a s s i s t with our assessment of
the School's level of compliance with Federal and State regulations
concerning student evaluation and placement. The consultants examined a
representative sample of 178 student f i l e s ; reviewed 11 cases that had
been the object of complaints or disputes involving ASDB; and interviewed
representatives of ASDB, the Arizona Department of Education, and local
school d i s t r i c t s . ( ' )
ASDB's Evaluation And Placement
Process Has Markedlv Improved
Substantial progress has been made toward upgrading student evaluation
and placement at ASDB. Our previous review of ASDB revealed s i g n i f i c a n t
problems with the evaluation and placement process. Since then, steps
have been taken to address or ameliorate many of these problems.
1987 audit found major ~ roblems - Our Office f i r s t reviewed the
evaluation and placement process at ASDB in 1987. A t that time, we found
that ASDB made admission and placement decisions without involving local
schoc d i s t r i c t s . For example, Tucson Unified School D i s t r i c t personnel
were aware of only 6 of 104 students from their d i s t r i c t that were
( 1 ) The c o n s u l t a n t s ' r e p o r t i s a v a i l a b l e f o r review by i n t e r e s t e d i n d i v i d u a l s . Copies of
the report may be requested from the O f f i c e o f the Auditor General.
enrolled at ASDB. We found ASDB's admissions policy was inadequate
because i t did not include a system to involve school d i s t r i c t s i n the
r e f e r r a l and placement process at ASDB.
S i a n i f i c a n t im~ rovement has occurred - ASDB has addressed many of the
concerns raised i n our previous report and now encourages school d i s t r i c t
and parent involvement in the evaluation and placement process at
ASDB.(') For example,
To encourage d i s t r i c t involvement, ASDB has changed the way i t
schedules evaluation and placement meetings. Meetings for a
d i s t r i c t ' s students are now scheduled around the same time to make i t
more convenient for d i s t r i c t o f f i c i a l s to p a r t i c i p a t e .
N o t i f i c a t i o n of scheduled meetings has also improved. Although some
occasional problems s t i l l e x i s t , 95 percent of the parents we
surveyed said ASDB provided adequate notice of meetings scheduled for
t h e i r Almost 90 percent of school d i s t r i c t o f f i c i a l s
that had students evaluated at ASDB in the past three years reported
that ASDB rovided adequate n o t i f i c a t i o n of evaluation and placement
meet ings. t 37
Teleconferencing has been used in some instances when parents or
d i s t r i c t o f f i c i a l s were unable to attend.
ASDB now keeps d i s t r i c t s better informed of the students from their
d i s t r i c t s that are enrolled in ASDB programs. S t a f f a t both ASDB- Tucson
and PDSD have been assigned r e s p o n s i b i l i t y for keeping school d i s t r i c t s
informed of the students placed in their programs.
In addition to the School's e f f o r t s , statutes and p o l i c i e s have been
revised to require school d i s t r i c t involvement in student evaluation and
placement.
( 1 ) Despite ASDB's e f f o r t s , d i s t r i c t s do not always p a r t i c i p a t e in evaluation and
placement meetings. In reviewing student f i l e s a t ASDB- Tucson, the consultant team
found t h e s i g n a t u r e of school representatives on only 63 percent of i n i t i a l placement
forms and 72 percent of three- year reviews, although a d i s t r i c t representative i s
required to attend these meetings and sign these forms.
( 2 ) Questionnaires were sent to a s t a t i s t i c a l l y valid sample of 233 parents. Completed
surveys were received from 177 parents, f o r a response rate of 76 percent.
( 3) Surveys were also sent to a l l 233 local school d i s t r i c t special education d i r e c t o r s .
Completed surveys were received from 159 d i s t r i c t s , for a 68 percent response r a t e .
Ninety respondents reported that students from thei r d i s t r i c t had been evaluated a t
ASDB in the past t h r e e y e a r s .
Arizona Revised Statutes ( A. R. S.) 915- 1342. was amended in 1988 to
require that school d i s t r i c t o f f i c i a l s d i r e c t the evaluation and
placement process and p a r t i c i p a t e i n evaluation and placement
meetings at ASDB.
ASDB developed a new admissions policy i n 1989 that r e q u i r e s ' a l l
r e f e r r a l s for evaluation and placement in ASDB programs to be made
through the student's d i s t r i c t of residence. The policy also
establishes guidelines f o r evaluation and placement that require
collaboration between ASDB and the local school d i s t r i c t .
ASDB's Board of Directors also established a policy expressing ASDB's
commitment to serve only those students that cannot be adequately
served in a regular classroom with the use of supplemental aids and
services.
The consultant team that assisted with our review reported that ASDB has
made " enormous strides i n the past f i v e years." These consultants found
no major flaws i n the evaluation and placement process.
Placement Of Multiply Handica~ ped Students
Continues To Generate Controversy
Problems continue i n placing students w i t h m u l t i p l e handicaps. Since
1987, ASDB has expanded i ts programs to serve sensory- impai red, mu I t i p ly
handicapped students. However, placement of these students s t i l l
generates some controversy, and the factors generating controversy need
to be addressed. Services for sensory- impaired students with severe
emotional disorders also need to be developed to ensure compliance with
Federal requirements.
Services to m u l t i p l v handicap~ ed students expanded since 1987 - Programs
for m u l t i p l y handicapped students at ASDB have increased since 1987. Our
previous report recommended that ASDB expand e f f o r t s to meet the needs of
sensory- impaired students with additional handicaps. In many instances,
ASDB was found to be better suited to provide programs for these students
than local d i s t r i c t s . However, at that time ASDB appeared to be
reluctant to serve multiply handicapped students. ASDB has taken a
number of steps to expand services for m u l t i p l y handicapped students
since 1987. The number of educational classes for m u l t i p l y handicapped,
severely sensory- impaired ( MHSSI) students at ASDB's Arizona Diagnostic
Testing and Education Center ( ADTEC) in Tucson was increased from f i v e to
seven. In addition, two classes for MHSSl students were established at
the Phoenix Day School for the Deaf. The North Central Regional
Cooperative, which began operating in 1989, also serves 23 MHSSl students.
Placement of m u l t i ~ l vh andicaoped students continues to create problems -
Although ASDB has expanded programs for multiply handicapped students,
placement of these students s t i l l creates problems. In interviews with
the consultant team and in responses to our survey, some school d i s t r i c t s
expressed concerns about ASDBts willingness to accept multiply
handicapped students as indicated by the following responses:
ASDB needs to accept in their program in Tucson students who are
severe in nature. I t has been my experience that they have only
taken those students that offer minimal challenge to them.
Although things have improved recently, ASDB has not wanted to
accept students who are handicapped ( i n addition to the sensory
impairment). The strange outcome is that ASDB tends to take the
less severely handicapped students, while the public schools
take the more complex students.
The reason we do not refer many students to ASDB programs i s
because h i s t o r i c a l l y they do not accept our referred students
who have " other" disabi l i t i e s .
Some local d i s t r i c t s have f i l e d complaints with the Arizona Department of
Education ( ADE) regarding the evaluation and placement of students at
ASDB. Members of the consultant team reviewed 11 complaints i d e n t i f i e d
by ADE and found that these cases t y p i c a l l y involved students with
" extremely challenging problems requiring the design of individualized
educational and other intervent ion programs."(')
Factors leadinq to problems need to be addressed - Several factors appear
to be responsible for the controversies involving multiply handicapped
students.
( 1 ) The c o m p l a i n t s c o n c e r n i n g ASDB p r i m a r i l y i n v o l v e d sensory- impaired students w i t h
severe emotional d i s o r d e r s , mental r e t a r d a t i o n , o r l i m i t e d E n g l i s h p r o f i c i e n c y .
ASDB's role i n serving sensory- impaired students with additional
handicapping conditions i s unclear. ASDB statutes c o n f l i c t and may lead
to disputes over which students the School should serve. Some school
d i s t r i c t representatives and ADE o f f i c i a l s believe that ASDB i s required
to serve all sensory- impaired students that cannot be served by t h e i r
d i s t r i c t of residence. An ADE o f f i c i a l c i t e d Arizona Revised Statutes
( A. R. S.) $ 15- 1343( A):
A person i s e n t i t l e d to an education in the school for the deaf
and the b l i n d without charge i f he i s a resident of the state,
age s i x to twenty- one years and sensory impaired to an extent
that he cannot acquire an appropriate education i n the school
d i s t r i c t of residence.
ASDB, i n contrast, has argued that the School i s only part of a continuum
of services required by sensory- impaired students. A. R. S. $ 15- 1342( F)
provides some support for t h i s p o s i t i o n :
I f the chief administrator of the school or accommodation school
or his designee and the superintendent of the school [ ASDB]
determine that the school [ ASDB] cannot provide the appropriate
educational programs and services needed by the c h i l d , they
shall locate or establish a program to meet the c h i l d ' s needs i n
consultation with the department of education and any other
appropriate state agency.
The cost of serving sensory- impaired students t h a t are m u l t i p l y
handicapped may also generate controversy over who w i I I serve these
students and who w i l l pay for services. ASDB and ADE o f f i c i a l s agree
that current funding levels do not match the cost of serving special
education students. An ASDB o f f i c i a l has said that t h i s makes i t
d i f f i c u l t for them to add new students during the year. For f i s c a l year
1990- 91, ASDB received $ 12,210 from i n s t i t u t i o n a l voucher payments for
each student c l a s s i f i e d as MHSSI. However, ADE reports that ASDBrs per
pupi I cost for MHSSI students was $ 31,451 for the same period.
The problems associated with serving m u l t i p l y handicapped students cannot
be resolved by ASDB alone. In November 1991, representatives of ASDB met
with ADE o f f i c i a l s to discuss the complaints received by ASDB. In
January 1992, ASDB and ADE established a voluntary task force to review
ASDB's admissions policy and role. Although the group discussed several
issues, many remain unresolved, and add i t ional measures are needed to
reduce controversy over ASDBts role. A more formalized task force needs
to be established by the Legislature to examine ASDBts role i n serving
sensory- impaired, m u l t i p l y handicapped students and the adequacy of
current funding levels. The task force should be directed by ADE and
include representatives of ASDB, local school d i s t r i c t s , and the
Department of Health Servicest Behavioral Health Division. In addition,
l e g i s l a t i v e action may be needed to c l a r i f y ASDB's statutory role and
address current funding problems.
Prwram for students with severe emotional disorders needed - Arizona may
not comply with Federal requirements because i t lacks some necessary
services for sensory- impaired students with severe emotional disorders.
In recent years, several sensory- impaired students with severe emotional
disorders have been referred to ASDB for placement. ASDB and local
school d i s t r i c t s have found these students d i f f i c u l t to serve because
they may exhibit aggressive behaviors that necessitate placement i n a
hospital or residential treatment s e t t i n g . In addition, these students
require the services of trained counselors and therapists that are also
s k i l l e d i n working with the sensory- impaired.
Arizona currently lacks some services for sensory- impaired students with
severe emotional disorders. According to our consultants, the State does
not have psychiatric treatment f a c i l i t i e s designed to handle
sensory- impaired students with severe emotional disorders. A recent
report by the Statewide Behavioral Task Force on Deafness also indicates
Arizona does not have adequate behavioral health services for the deaf
and hard of hearing. As a r e s u l t , the State may not comply with Federal
special education requirements. The Federal Individuals with D i s a b i l i t y
Education Act ( IDEA) requires that states provide a l l c i t i z e n s w i t h a
free, appropriate education. I n a d d i t i o n , IDEA requires that states have
a f u l l range of placement options available.
ASDB has recognized the need to improve services for t h i s population of
students.(') However, providing services to sensory- impaired students
with severe emotional disorders can be costly. According to our
consu l tants , schoo l - based programs can cost between $ 60,000 and $ 120,000
per pupi I annually, and hospital- based programs can cost over $ 1,000 per
day.( 2) To date, ASDBfs e f f o r t s to establish a special program have been
unsuccessful. Development of such services w i l l require additional
funding and the active p a r t i c i p a t i o n of ADE, ASDB, local school
d i s t r i c t s , and the Department of Health Services' Behavioral Health
Division.
( 1) ASDB submitted a grant proposal to the U. S. Department of Education seeking funds f o r
a j o i n t program w i t h a Tucson p s y c h i a t r i c hospital . The School has also worked to
obtain funding f o r the program through the Department of Health Services' Behavioral
Health D i v i s i o n .
( 2 ) Currently, one Arizona student i s i n an I l l i n o i s program f o r hearing- impai red students
w i t h severe emotional disorders. This student was placed i n a h o s p i t a l s e t t i n g f o r 60
days a t an average cost of $ 1,335 per day. The student i s now i n the program's
therapeutic group home a t a cost of $ 212 t o $ 262 per day.
RECOMMENDATIONS
ASDB should continue i t s e f f o r t s to improve the evaluation and
placement process. S p e c i f i c a l l y ,
The School should take steps to ensure i t consistently complies
with the statutes and regulations governing student evaluation
and placement, and
ASDB should work to achieve f u l l parental and school d i s t r i c t
p a r t i c i p a t i o n i n the evaluation and placement process.
The Legislature should establish a task force to address problems
concerning the placement of m u l t i p l y handicapped students. The task
force should be led by ADE and include representatives from ASDB,
local school d i s t r i c t s , and the Department of Health Services'
Behavioral Health Division. S p e c i f i c a l l y , t h i s group should
Clar i fy ASDB's role i n serving sensory- impai red students with
multiple handicaps and severe emotional disorders.
Examine the adequacy of funding levels for sensory- impaired
students w i t h m u l t i p l e handicaps.
Determine the need for and type of special programs for sensory
impaired students with severe emotional disorders.
Develop recommendations and report findings to the Legislature
Based on the recornendations of the task force, the Legislature
should consider revising ASDB's statutes to c l a r i f y the School's role
i n serving the sensory impaired.
FINDING IV
THE BOARD NEEDS TO IMPROVE ITS GOVERNANCE
OF THE ARIZONA SCHOOL FOR THE DEAF AND THE BLIND
The Board of D i r e c t o r ' s oversight and control of the Arizona School for
the Deaf and the Blind ( ASDB) needs strengthening. In recent years,
s i g n i f i c a n t leadership and financial management problems have developed
without the Board's knowledge. Although the Board has taken some steps
to improve i t s oversight and control of ASDB, further action i s needed to
ensure e f f e c t i v e governance.
The statutes assign primary r e s p o n s i b i l i t y for proper operation of ASDB
to the Board o f D i r e c t o r s . Although the Board hires a Superintendent to
provide day- to- day management of the school, the Superintendent has very
few d i r e c t s t a t u t o r y r e s p o n s i b i l i t i e s other than to h i r e other School
personnel. A l l other major r e s p o n s i b i l i t i e s ( v i z . , budget development
and approval, control of expenditures of appropriated funds,
establishment of personnel p o l i c i e s , development of c u r r i c u l a and
programs, disposition of t r u s t lands, and control over t r u s t fund
investments and expenditures) rest with the Board.
Board Oversiqht
And Control Is Weak
Because the Board o f D i r e c t o r s ' oversight and control of ASDB operations
i s weak, s i g n i f i c a n t management and financial problems have arisen
without the Board's knowledge. The Board lacks the p o l i c i e s and
procedures needed to guide s t a f f and secure the information necessary to
d i r e c t School operations e f f e c t i v e l y . I n e f f i c i e n t and unproductive Board
meetings a l s o c o n t r i b u t e to inadequate governance.
The Board was unaware of ~ roblems - U n t i l informed by l e g i s l a t o r s in July
1991, ASDB Board members state they were unaware of the serious
d i s s a t i s f a c t i o n of ASDB s t a f f , parents, and some l e g i s l a t o r s w i t h the
former Superintendent's management of ASDB.(') Matters contributing to
d i s s a t i s f a c t i o n w i t h ASDB leadership in 1991 include the following:
Concerns about an excessive number of administrators
Reducing services to students but not administrators during a major
reduction i n force
a Funding of administrators' frequent travel t o out- of- state conferences
Frequent a i r travel from Tucson to Phoenix and rental of luxury cars
in Phoenix by the former Superintendent
Problems with s t a f f morale and management communication
The former Superintendent's request to the Legislature, without the
Board's knowledge, for postponement u n t i l 1994 of the 1991- 1992
Sunset Audit of ASDB
Inclusion of a $ 54,000 clock tower in construction plans for the
Tucson campus, in spite of the objections of s t a f f , parents, and
legislators
After being informed of these problems, the Board met several times to
address the s i t u a t i o n . During t h i s time, the Superintendent relinquished
his position and was reassigned as the Board's Project Specialist. The
former Superintendent served in this posit ion at a salary of $ 74,500 from
July 1991 to June 1992. The pos i t i on was funded using savi ngs from the
vacant Superintendent position.
Performance of Former Superintendent not evaluated - Many of the problems
might not have developed i f the Board had more actively monitored and
evaluated the performance of the former Superintendent. According to
BOARDSMANSHIP, the manual for school boards pub1 ished by the Arizona
School Boards Association, evaluation of the Superintendent is one of a
board's most powerful tools for managing a school in the public
interest. However, in four of the five years preceding the ASDB
Superintendent's removal in 1991, the Board did not formally evaluate his
performance.
( 1) The Board was also unaware of the questionable expenditures of nonappropriated funds
we found during t h i s audit ( see Finding 11, page 19).
Policv auidance i s lacking - Although part- time, the Board could exercise
more oversight by developing better operating p o l i c i e s for the s t a f f and
school .
According to the BOARDSMANSHIP manual, a school board i s responsible for
adopting p o l i c i e s under which administrators and teachers may operate the
school. Although Boards should not be involved i n the day- to- day
management of the school, they should, through p o l i c i e s , provide clear
d i r e c t i o n for the administration of the school. Among p o l i c i e s needed,
the manual states, i s a w r i t t e n communications policy that provides for a
planned, systematic, two- way program of comunication between the
i n s t i t u t i o n and i t s internal and external publics.
As yet, the Board has no w r i t t e n communications p o l i c y t o ensure a
systematic d i a l o g w i t h i t s internal publics ( ASDB administrators, s t a f f ,
students) or i t s external publics ( students' parents, advocacy groups,
the Legislature, the media). The need for a communications policy i s
p a r t i c u l a r l y important because the policy in force p r i o r to August 1991
was perceived as p r o h i b i t i n g s t a f f input to the Board.
Furthermore, the Board provides ASDB administrators and s t a f f r e l a t i v e l y
l i t t l e other w r i t t e n policy guidance, except on personnel matters,
compared to the policy guidance provided at s i m i l a r , highly regarded
special schools in other states or at an e f f e c t i v e l y managed Arizona
pub1 i c school . ( ' ) ASDB Board p o l i c i e s , for example, provide l i t t l e of
the extensive policy guidance provided at other schools regarding
curricula and instruction, student behavior and r e s p o n s i b i l i t i e s , general
school administration, educational philosophy, provision of support
( 1 ) To evaluate the scope o f p o l i c y d i r e c t i o n provided ASDB, we compared p o l i c y manuals o r
p o l i c y manual i n d i c e s o f h i g h l y regarded special schools i n several o t h e r s t a t e s , as
w e l l as t h e N a t i o n a l School Boards A s s o c i a t i o n pol i c y c l a s s i f i c a t i o n system index and
the index o f the p o l i c y manual of the Mesa pub1 i c schools, which employs the NSBA
system, w i t h the ASDB manuals.
services, relations with other agencies, or communications and community
relations. In addition, the Board has not adopted policies for i t s
operations except for the election o f o f f i c e r s and attendance, the later
of which has not been enforced.
Board meetinas also contributed to aovernance ~ r o b l w s- I n e f f i c i e n t and
unproductive Board meetings also limited the Board's a b i l i t y to govern.
During our i n i t i a l interviews, Board members expressed dissatisfaction
and f r u s t r a t i o n w i t h the Board's procedures and accomplishments. They
noted that meetings focus more on " housekeeping" than on important policy
issues. Our review and analysis of the minutes of 28 regular Board
meetings held from July 1989 through February 1992, and observation of
Board meetings over a six- month period confirms this.
Although much of the Board's emphasis on routine matters is the result of
i t s attempts to exercise greater control over school a f f a i r s , the Board's
effectiveness in these e f f o r t s is limited by the lack of policies and
procedures governing their review and Board members1 i n a b i l i t y to review
information prior to the meeting.
As a result, Board meetings ( which usual ly consist of a pub1 ic study
session, closed executive session, and a public meeting) t y p i c a l l y last
about four hours and, frequently, as long as five or six hours. When
Board meetings habitually exceed two and one- half hours, the
BOARDSMANSHIP manual states the reason for this is either consideration
of administrative items more properly the province of school
administrators or inadequate preparation by Board members. Both problems
appear to contribute to the excessive length of ASDB Board meetings.
ASDB Board a c t i v i t i e s focus predominantly on routine business and
personnel matters, and some Board members residing outside Tucson
complain that information packages frequently arrive too late to permit
review before meetings.
Action To lm~ rove
Governance Is Needed
Although the Board has taken some steps to address i t s governance
problems, further action is needed. I f governance is not improved
through the Board's e f f o r t s , other governance systems should be
considered.
The Board has beaun to address aovernance oroblems - In recognition of
the Board's problems i n governing ASDB, many of which Board members
discussed candidly with us, the Board has taken some steps to improve
governance. For example, the Board in i t s public study sessions includes
discussion of upcoming Board agenda items, c a l l s routinely for public
comment on issues during i t s regular meetings, and requires separate
readings at successive monthly meetings before acting on the most
important issues i n order to promote dialog with s t a f f , students,
parents, and the public. To enhance dialog, the Board has rescinded a l l
r e s t r i c t i o n s on s t a f f communications with Board members. The Board also
contracted for Arizona School Board Association assistance i n conducting
the search for a new Superintendent. The Board has also completed a
Request for Proposal ( RFP) for outside help i n preparing a comprehensive
policy manual. However, funding has not been obtained. In addition, the
Board investigated the p o s s i b i l i t y of an outside review of ASDB
management needs, but the review is being held in abeyance pending
completion of t h i s audit. F i n a l l y , the Board brought some t r u s t fund
expenditures under i t s direct control.
Further action i s reauired - The Board needs to follow through on some of
the tentative steps i t has already taken as well as take additional
measures to govern ASDB more e f f e c t i v e l y . Among actions the Board should
take are the following additional measures.
Secure and commit the resources needed to develop a comprehensive,
codified policy manual to guide ASDB administrators and s t a f f .
Develop and publish bylaws that include prompt and regular
attendance, and conduct i t s meetings in accordance with them.
Improve i t s oversight of the Superintendent and regularly evaluate
his or her performance.
Improve i t s oversight and control of nonappropriated funds ( see
Finding I I ).
Ensure that i t s members receive the training needed to conduct Board
meetings e f f e c t i v e l y .
Ensure that Board members have information packets at least seven
days before the Board's regular public meetings.
Other aovernance svstems are possible - I f governance i s not improved by
the Board's e f f o r t s , other governance systems could be considered. There
are a v a r i e t y o f service delivery models for sensory- impaired pupils and,
according to our consultants and Federal o f f i c i a l s , highly regarded
special schools function within each model. Most of these special
schools operate under the d i r e c t i o n of t h e i r states' board of education;
however, s p e c i f i c a l l y appointed boards, such as the ASDB Board, d i r e c t
the operation of these special schools in 14 states. In three states,
these special schools operate under the d i r e c t i o n of the state board of
regents.
RECOMMENDATIONS
1. The Board should develop a comprehensive set of operating p o l i c i e s t o
guide i t s a c t i v i t i e s and ASDB's a c t i v i t i e s .
2. The Board should thoroughly evaluate the Superintendent's performance
each year.
3. The Board should ensure that i ts members receive the t r a i n i n g needed
to perform t h e i r duties e f f e c t i v e l y .
4. The Board should ensure that every member receives information for
i t s meetings in time to review the information before the meetings.
FINDING V
ASDB'S ROLE AS A STATEWIDE RESOURCE
IS NOW CLEARLY ESTABLISHED IN STATUTE; HOWEVER,
MORE NEEDS TO BE DONE TO FULFILL THIS MANDATE
Although ASDB now provides some services to local school d i s t r i c t s ,
additional e f f o r t s are needed to f u l l y develop the School's role as a
statewide resource. Since our 1987 audit, ASDB's statutes have been
amended to require that the School serve as a resource to local school
d i s t r i c t s throughout Arizona. ASDB has worked with d i s t r i c t s in north
central Arizona to develop a successful regional cooperative program for
sensory- impaired students. In addition, ASDB has provided a limited
quantity of resource services to school d i s t r i c t s ; however, these
services should be expanded.
ASDB Is Now Reauired To Serve As A
Resource To Local School Districts
ASDB's role in providing resource services to the public school community
i s now c l e a r l y established. In our 1987 report, we found that ASDB could
further develop i t s role as a statewide resource i n the education of the
sensory impaired. Since 1987, ASDB's statutes have been revised twice to
require t h a t ASDB provide resource services to local school d i s t r i c t s .
In 1987, l e g i s l a t i o n was passed that c a l l e d f o r the establishment of a
p i l o t program of regional cooperative services to be operated by ASDB.
The program was to provide a variety of services for p a r t i c i p a t i n g
d i s t r i c t s . In 1990, ASDB's statutes were again amended to mandate that
ASDB provide a number of services to school d i s t r i c t s , State i n s t i t u t i o n s
and other approved education programs. These changes establishing ASDB's
role as a resource to local school d i s t r i c t s are important for several
reasons.
Federal law requires that sttldents he placed in the least r e s t r i c t i v e
environment. Public Law 94- 142 presumes that disabled children w i l l
be educated with nondisabled children, unless these children cannot
be educated s a t i s f a c t o r i l y i n regular classes with the use of
supplementary aids and services. ASDB can o f f e r services that allow
d i s t r i c t s to serve some students that would otherwise be placed out
of d i s t r i c t .
ASDB can offer specialized services for the sensory- impaired that are
difficult for some districts to provide because of geographic factors
and the small number of sensory- impaired students. The 1988 Arizona
School Superintendent's Special Education Services Study found that
rural districts are typically small and often lack the resources to
offer an effective and efficient special education program.
ASDB has expertise in the education of sensory- impaired students that
some districts may lack. School districts sometimes find it
difficult to attract personnel that are trained to work with
sensory- impaired students because they may need staff on a part- time
or limited- term basis.
Finally, ASDB has facilities for the sensory- impaired that districts
may be unable to provide. Our consultants found that ASDB has
outstanding facilities for both hearing- impaired and
visually- impaired students.
Pilot Reqional Coo~ erative Proqram Has Been
Successful And Should Be Ex~ anded
The pi lot regional cooperative program administered by ASDB has shown
.. ne ; t, ,; ,,, m, resu! t s and shou! d be expanded. The program was establ ished in
north central Arizona in 1987 and has proven to be beneficial. As a
result, the ASDB Board of Directors should consider extending the program
to other areas of the State.
Overview of the ~ ilot reqional coo~ erative proaram - A pi lot regional
cooperative program was established by Senate Bill 1251 in 1987. This
legislation called for the creation of three regional service
cooperat i ves in f i sca I year 1987- 88 . ( ' I These cooperat i ves were to be
operated by ASDB through intergovernmental agreements with participating
school districts, and were to provide a variety of services, including
the following:
Educational programming
Evaluations, including audiological, psychological, and vision
assessments
Specialized related services, including orientation and mobility
training
( 1 ) The p i l o t program was o r i g i n a l l y scheduled to operate through f i s c a l year 1989- 90;
however, in 1990 i t was extended through f i s c a l year 1993- 94.
Specialized curriculum materials and equipment
Program and s t a f f development assistance
Assistance with screening, i d e n t i f i c a t i o n , and r e g i s t r a t i o n of
sensory- impai red pupi Is
In 1988, the State Board of Education determined that regional
cooperative programs would operate in north central, southeast, and
southwest ~ r i z o n a . ( ' ) Due to resource constraints, funding was provided
for the establishment of only one regional cooperative. The north
central region was selected as the pi l o t region because of the lack of
services i n that area and because of the a c t i v e i n t e r e s t shown by parents
and school d i s t r i c t s t o improve services.
The North Central Regional Cooperative began operating i n the f a l l of
1989. As of February 1992, 31 local school d i s t r i c t s were p a r t i c i p a t i n g
in the Cooperative, which was providing educational services to 84
students.
Pilot Droaram has been successful - The p i l o t regional cooperative
program has been quite successful during i t s f i r s t three years of
operation. Parents of students i n the North Central Regional Cooperative
have expressed high levels of sat isfact ion with the program. Ninety- one
percent of the parents responding to our survey favored continuing the
program(*), and a majority indicated their children are receiving a wider
range of special services, are spending more time receiving services, and
are receiving a higher q u a l i t y of services since the program was
established. Many parents commented on the benefits of the program. A
sample of t h e i r comments follows.
( 1 ) The n o r t h c e n t r a l r e g i o n i n c l u d e s most o f Yavapai , Coconino, and n o r t h e r n Mohave
Counties. The southeast r e g i o n i n c l u d e s the Tucson metropol i tan area, and Graham,
Cochi se, Santa Cruz, and southern Greenlee Counties. The southwest r e g i o n i n c l u d e s
Yuma and southern La Paz Counties.
( 2 ) As p a r t of o u r r e v i e w , q u e s t i o n n a i r e s were sent t o the parents of a l l 72 students then
r e c e i v i n g services through the Cooperative. Completed surveys were r e c e i v e d from the
parents of 64 students, f o r a response r a t e o f 89 p e r c e n t .
The services being provided would not be made available without
the ASDB Cooperative Program. The School does not have
personnel and/ or equipment to provide s a t i s f a c t o r i l y for
visually- disabled students. Guidance from s p e c i a l i s t s i s needed
and should be continued.
Since our son started junior high t h i s year, and started
receiving help, he has started to enjoy reading and school. His
grades were a l l A's and B's on h i s last report card. I cannot
praise the program enough.
Before t h i s program, we had to personally f i g h t for every
service our daughter needed to compensate for her hearing loss.
Now we have knowledgeable and supportive personnel and the
services are available as needed.
School d i s t r i c t o f f i c i a l s also appear to strongly support the program.
We surveyed local o f f i c i a l s from the North Central Regional Cooperative
regarding the program.(') Of those respondents that expressed an
opinion, a l l believed the program should be continued. In addition, many
d i s t r i c t o f f i c i a l s indicated they would have d i f f i c u l t y providing
comparable services on t h e i r own. The high level of p a r t i c i p a t i o n i n the
North Central Regional Cooperative also indicates the program i s
b e n e f i c i a l t o local school d i s t r i c t s . Although involvement i n the North
Central Regional Cooperative i s voluntary, most d i s t r i c t s within the
region's boundaries are p a r t i c i p a t i n g in the program. In addition, four
school d i s t r i c t s outside the region have joined the Cooperative or
receive services through the program.
The program's success i s also indicated by the increased number of
students served. North Central Regional Cooperative s t a f f have
i d e n t i f i e d sensory- impaired students that had not previously been served
or were underserved. Prior to the establishment of the North Central
Regional Cooperative, 63 pupils within the north central region were
c l a s s i f i e d as sensory impaired. During the f i r s t year of the program,
Cooperative s t a f f i d e n t i f i e d 49 additional students with hearing or vision
( 1 ) Surveys were sent to the Special Education Directors i n the 31 local school d i s t r i c t s
t h a t a r e members of the North Central Regional Cooperative. Surveys were returned by
22 d i s t r i c t s , for a response rate of 71 percent.
loss. In addition, Cooperative personnel found that 18 of the 63
students c l a s s i f i e d as sensory impaired were not receiving needed
services p r i o r to the program. These children were enrolled i n a school
d i s t r i c t program without a special teacher for the hearing or v i s u a l l y
impai red.
The reaional c o o ~ e r aitv e proqram should be exaanded - Regional service
cooperatives should be established i n the southeast and southwest regions
of the State. Monies saved from the elimination of unnecessary
administrative positions ( see Finding I, page 7) could be used to cover
the base- level administrative costs of adding two more regional
cooperative programs, which ASDB estimates to be $ 291,300.
Services Provided To Local School Districts
Are Limited And Should Be Increased
Although ASDB has provided some services to local school d i s t r i c t s , these
services need to be expanded. In addition to d i r e c t services to students
provided through the regional cooperative program, statutes also require
ASDB to provide a wide range of resource services to school d i s t r i c t s and
other educational i n s t i t u t i o n s in Arizona. However, to date ASDB's
e f f o r t s have been limited. More needs to be done i f ASDB i s to f u l f i l l
i t s mandate as a resource to local school d i s t r i c t s .
Am i s required to arovide a v a r i e t y of resource services - In 1990,
ASDB's statutes were amended to require the School to serve as a
statewide resource i n the education of the sensory impaired ( ASDB
requested t h i s change). Arizona Revised Statutes ( A. R. S.) 915- 1302( D)
requires ASDB to provide a wide range of resource services, including but
not limited to the following:
Assessments
Special curriculum
Equipment and materials
Supplemental related services
Special short- term programs
Program planning and s t a f f development
Information services for parents, families, and the public
Research and deve l opment to promote improved educat i ona l programs and
services
ASDB i s to provide these services to school d i s t r i c t s , State
i n s t i t u t i o n s , and other approved educational programs.
Limited resource services have been ~ r o v i d e d - Although ASDB has provided
some services to local school d i s t r i c t s , programs have yet to be
developed f u l l y i n many services areas. ASDB provides several types of
assessment services to local school d i s t r i c t s . ( ' ) The School has also
developed specialized curriculum materials that are available to s c h o ~ l
d i s t r i c t s . However, ASDB s t i l l needs to expand or develop many services,
including the following:
Evaluation services - A needs assessment conducted by ASDB in 1991
found that student evaluation i s the resource service most needed by
school d i s t r i c t s . However, ASDB has been unable to keep up with the
demand for these services. Our survey of local school d i s t r i c t s
found that some d i s t r i c t s have been placed on a waiting l i s t for
evaluation services. In addition, two d i s t r i c t s reported they had
been refused evaluation services by ASDB. The consultant team
reports that additional resources would need to be allocated t o
ensure that student evaluation services are provided i n a timely
fashion.
Special short- term proqrams - Our consultants recommend that " serious
consideration should be given to expanding ASDB on- campus programs to
a full- year program either by summer programming or short- term
intensive i n s t r u c t i o n for students who wouldn't be enrolled f u l l
time." The consultant team notes that ASDB could o f f e r programs in
o r i e n t a t i o n t r a i n i n g , B r a i l l e , computers, and American Sign Language.
Providina needed equiment and materials - The North Central Regional
Cooperative has a materials and equipment center in i t s Flagstaff
o f f i c e that supplies materials to teachers in the region. ASDB's
Acting Superintendent has suggested establishing such a program on a
statewide basis. Equipment used by sensory- impaired students, such
as Brai l le writers and auditory trainers, could be purchased by ASDB
( 1) The School ' s Arizona Diagnostic Testing and Education Center ( AOTEC) performs in- depth
nine- week evaluations o f sensory- impai red students w i t h addi ti onal handicapping
condi ti ons . ASDB a1 so conducts r o u t i n e student evaluations , c a l l ed Pub1 i c School
Assessments ( PSAs), f o r school d i s t r i c t s t h a t l a c k the expertise t o evaluate
sensory- impai red students themselves.
or cot
d i s t r i
serve
Brai I I
lected from d i s t r i c t s that no longer need i t and distributed to
cts with a demand for this equipment. The center could also
as a clearinghouse for teaching materials, such as books in
e and audio- visual materials.
In addition, ASDB has made l i t t l e progress in creating s t a f f development
programs for local school d i s t r i c t personnel or public information
programs. The School also made l i t t l e progress in providing supplemental
related services, such as orientation and mobility training, to students
in school d i s t r i c t programs.
School o f f i c i a l s c i t e resource constraints as the primary reason more
se rv i ces have not been rov i ded . ( ' ) However , the cost sav i ngs r ea l i zed
by eliminating nonessential administrative positions may provide funding
for expanded services to local d i s t r i c t s ( see Finding I, page 7).
RECOMMENDATION
1. ASDB's Board of Directors should consider the fol lowing steps to
f u l f i l l the School's mandate as a statewide resource.
a. Expand the regional cooperative program to the southeast and
southwest regions of the State.
b. Expand existing programs and develop new programs requi red by
A. R. S. $ 75- 1302( D).
c. Request the Legislature to allow savings generated from the
elimination of administrative positions be used to fund these
programs.
( 1 ) I n 1990, ASDB estimated i t would cost $ 250,000 t o develop resource s e r v i c e s .
FINDING VI
ASDB NEEDS TO COLLECT MORE
COMPREHENSIVE INFORMATION ABOUT ITS STUDENTS'
POST GRADUATION SUCCESS
The ASDB should increase i t s e f f o r t s to evaluate the success of i t s
graduates i n postsecondary employment and education. Evaluating student
outcomes i s an important measure of the School's success i n preparing
sensory- impaired students to lead f u l l , meaningful l i v e s . To date, ASDB
has collected only limited information about student a c t i v i t i e s a f t e r
graduation. Although the School has recently expanded follow- up of
graduates, i t needs to collect more systematic and comprehensive data.
Information About Student Outcome Is
An lm~ ortant Manaaement Tool
The success of ASDB graduates i s an important measure of the School's
performance. Arizona law establishes specific goals for the School. In
addition, parents and governing Board members also have expectations of
the School, p a r t i c u l a r l y in the areas of academic and vocational
preparation. These expectations are a l s o r e f l e c t e d in professional
l i t e r a t u r e .
Statutorv reauirements - Arizona law establishes d e f i n i t e expectations of
ASDB. A. R. S $ 15- 1302( B) provides: " The school shall be for the
education of sensory impaired persons, so that the persons educated there
may become self- sustaining and useful c i t i z e n s . " The Legislature further
expanded on the School's purpose in 1988 when i t added:
The purpose of the Arizona state school for the deaf and the
b i ind is to promote and maintain an educational opportunity of
adequate scope and q u a l i t y for sensory impaired children i n t h i s
state which w i l l lead to an adult l i f e of independence and
self- sufficiency, a meaningful personal, family and community
l i f e and, a useful productive occupational l i f e .
These goals, which are also included i n the School's mission statement,
require some type of follow- up. Without tracking students' progress
a f t e r graduation, the School cannot ascertain whether i t i s meeting i t s
goals.
Other ex~ ectations - Some parents of ASDB students also have d e f i n i t e
expectations about t h e i r c h i l d r e n ' s c a p a b i l i t i e s . Approximately 10
percent of the ASDB parents responding to our survey expressed concern
about t h e i r children's a b i l i t y to successfully compete a f t e r graduation.
Typical comments included the following:
I ' v e been pleased by [ my daughter's] progress i n many areas, yet
the world i s predominately hearing and unfortunately our kids
must l i v e mostly by their rules. To be taught how to cope i n
that world would be most b e n e f i c i a l .
Everyone i s & KJ s a t i s f i e d with accepting old [ ideas] regarding
education of the deaf. Students and faculty w i l l l i v e up to the
expectations set for them. I f these are low, t h e y ' l l respond
accordingly. ( emphasis in o r i g i n a l )
The parents' concerns are echoed by ASDB Board members' observations that
the School's expectations are too low, allowing students to graduate with
only marginal s k i l l s . These Board members want the Board to adopt
p o l i c i e s that w i l l lead to a more challenging, results- oriented education
for ASDB students.
Professional education l i t e r a t u r e also emphasizes student a b i l i t y to
succeed a f t e r graduation. One recent study of school- to- work t r a n s i t i o n
of deaf school graduates states:
Competitive employment has been viewed as the most desirable
outcome of the t r a n s i t i o n process, coupled with the capacit to
l i v e independently, socialize and engage in community l i f e . cur
( 1 ) Thomas E. A l l e n , Brenda W. Raslings, and A r t h u r N. S c h i l d r o t h , Deaf Students and the
School- to- Work T r a n s i t i o n ( B a l t i m o r e , MD: Paul H. Brooks Pub1 i s h i n g , C O . , I n c . , 1989),
page i x .
In addition, recent trends indicate that special education programs are
increasingly l i k e l y t o be evaluated i n terms of student a b i l i t y to
succeed i n a postschool environment. of the special education
outcome models presented i n a recent report from the National Center for
Educational Outcomes include postgraduation a c t i v i t y as an outcome
measure.(')
Information On Student
Outcome Is Limited
Despite the importance of outcome information, ASDB has collected l i t t l e
information in the past about students a f t e r they graduate. For example,
the most recent annual report ( 1989- 90) indicates that 73 percent of the
Class of 1990 are enrolled i n postsecondary educational programs.
Another 24 percent are employed or in job training programs. However,
this information i s based solely on the students' plans at time of
graduation. ASDB s t a f f do not contact students a f t e r graduation to
determine whether they accomplished t h e i r stated goals.
Although ASDB participates in a national survey of deaf school graduates,
the information collected is of limited value to the school because few
ASDB graduates respond to the survey. The highest response rate ( 19
percent) in the past f i v e years occurred in the 1990 survey; other years'
response rates ranges from 7 to 13 percent. In addition to i t s low
response rate, the survey i s limited because i t does not include
graduates of the Phoenix Day School for the Deaf, which has a larger
graduating class than the Arizona School for the Deaf. Moreover, the
School for the Blind does not conduct a systematic follow- up survey of
i t s graduates.
ASDB's limited follow- up a c t i v i t y and information about i t s graduates
appears to be typical of many state schools for the sensory impaired.
One of our consultants and others with experience in conducting post
( 1 ) The N a t i o n a l Center on Educational Outcomes i s a c o l l a b o r a t i v e e f f o r t of the N a t i o n a l
A s s o c i a t i o n o f State D i r e c t o r s o f S p e c i a l Education, the U n i v e r s i t y o f Minnesota, and
St. Cloud State U n i v e r s i t y . The C e n t e r ' s mission i s t o p r o v i d e n a t i o n a l l e a d e r s h i p i n
i d e n t i f y i n g educational outcomes f o r students w i t h d i sabi 1 i ti es and developing a
system o f i n d i c a t o r s f o r m o n i t o r i n g those outcomes.
graduation outcome evaluations suggest that few, i f any, schools
d i l i g e n t l y track graduates.
ASDB Needs To Expand
Follow- Up Of Graduates
Given the importance of outcome evaluation to judging compliance with
statutory goals and other expectations, ASDB should expand the
information i t c o l l e c t s about i t s graduates. The limited information
currently avai lable suggests that some ASDB graduates may lack the ski l Is
necessary to lead independent, s e l f - s u f f i c i e n t lives. Although ASDB has
recently i n i t i a t e d more systematic follow- up a c t i v i t i e s , additional
e f f o r t s are needed.
Available information - A l though ASDB lacks comp l ete i nformat ion about a l l
of i t s graduates, the information that i s available indicates some
graduates may not be prepared to successfully continue t h e i r education or
gain employment. As previously noted, parents and Board members
expressed concern about the low levels of achievement of ASDB graduates,
p a r t i c u l a r l y i n reading. Nationally, reading levels f o r deaf school
graduates have persisted at the t h i r d - and fourth- grade median levels f o r
two decades. One ASDB faculty member noted that such s k i l l levels are
c h a r a c t e r i s t i c of even the most i n t e l l i g e n t deaf school graduates and can
l i m i t t h e i r opportunities in college or work.
ASDB s t a f f obtain some information through contacts with vocational
r e h a b i l i t a t i o n counselors serving graduates. For example, the vocational
s t a f f at both the Tucson campus and PDSD indicated they obtain feedback
and information on individual graduates during t h e i r contacts with
vocational r e h a b i l i t a t i o n counselors. These counselors report that ASDB
graduates vary in their a b i l i t y to further their education or obtain
work. Specific problem areas noted include independent l i v i n g ,
mathematics and s p e l l i n g , reading and w r i t i n g , and a lack o f motivation
and i n t e r e s t .
Recent efforts - ASDB has recently increased i t s e f f o r t s to obtain follow
up information on students a f t e r graduation. In 1991, ASDB s t a f f
conducted a follow- up survey of the 54 ASDB- Tucson students that
graduated from 1987 through 1991. The survey found that 17 students were
employed; 20 were in postsecondary education programs; 13 were
unemployed; and 4 were out o f s t a t e and no information was available
about them. The vocational counselor at Phoenix Day School for the Deaf
was also able to provide current status information about 1990 and 1991
graduates.
The 1991 follow- up survey provides a more r e a l i s t i c description of
graduates' a c t i v i t i e s than the information routinely presented in the
ASDB annual report; however, the survey i s s t i l l too limited to serve as
a useful indicator of student outcome. The major l i m i t a t i o n of the
survey i s that i t provides very l i t t l e information about the types of
employment, wages, and quality of the graduates1 lives. Such information
would indicate whether the School is meeting the goals set by law or
student and parent expectation. Similarly, knowing only that students
are in postsecondary education programs provides l i t t l e information about
the type of programs or students' success.
ASDB s t a f f indicated they plan to expand on the survey of graduates from
1987- 1391 by following up on students three to six months after
graduation. While this e f f o r t i s a good f i r s t step, i t may s t i l l provide
only limited information because graduates may take a few years to s e t t l e
into a career or job after graduation.
I f ASDB is to adequately evaluate i t s effectiveness, the School needs to
expand i t s e f f o r t s to track students from a l l schools, campuses, and
programs. To do t h i s , s t a f f should develop a survey designed t o c o l l e c t
information about graduates' employment, education, income, and other
s i g n i f i c a n t a c t i v i t i e s over a multiyear period. The survey design should
also provide for comparing graduates' a c t i v i t i e s and achievements to the
established goal of a meaningful and productive l i f e . Such an e f f o r t
would require the School to allocate additional resources for outcome
evaluation.
RECOMMENDATIONS
1. ASDB shou l d des i gn a comp rehens i ve outcome eva l uat ion mode l based on
the School's statutory goals.
2. ASDB should designate staff to carry out the activities required by
the design. The designated staff should be given adequate time to
complete all required tasks.
3. ASDB should include the results of its outcome evaluation in its
annual report and in a report to the Legislature.
OTHER PERTINENT INFORMATION
During our audit, we collected information on ASDB teaching methods and
c u r r i c u l a as well as the School's construction program.
Teachina Methods And Curricula
As part of their review, our consultants reviewed ASDB c u r r i c u l a and
teaching methods. Although they found the c u r r i c u l a and methods to be
good, the consultants also found that some equipment i s obsolete,
especially i n the School for the Blind.
Teachinq methods and c u r r i c u l a are comnended - The consultants found
that ASDB teaching methods r e f l e c t contemporary thought and trends i n
sensory- impaired education, and report that ASDB teaching methods and
curricula at both campuses are exemplary in some areas and good i n
others. They note that ASDB's Independent Living Center provides
occupational studies and consumer education. According to the
consultants, ASDB's Transition Program, which helps student and parents
look at po. ssible postgraduation employment opportunities, is unusually
strong and managed in a creative way. The consultants state that ASDB
s t r i v e s for an up- to- date approach in i t s programs, and they agree, with
the favorable accreditation reports ASDB has received.
Consultants also commended the following special programs
@ The Re~ ional Services Proqram, which uses q u a l i f i e d local personnel
to provide services to preschool, sensory- impaired children that l i v e
i n sparsely populated areas and might otherwise not be served.
The Arizona Diaanostic Testinq and Education Center, which provides
diagnostic and educational services for multiply handicapped,
severely sensory- impaired children.
The North Central Reqional Cooperative, which provides i t i n e r a n t
services to the sensory- impaired pupi Is of 31 p a r t i c i p a t i n g school
d i s t r i c t s in Coconino, Yavapai, and parts of Mohave, Navajo, and Gila
Counties under a p i l o t program i n s t i t u t e d in 1989.
Special eauiment shorta~ es e x i s t - According to the consultants,
equipment provision i s uneven and, since the 1987 audit, some s i g n i f i c a n t
shortages have developed, i n large part as a result of midyear budget
cuts. Budget data confirm that i n f i s c a l years 1987- 88 through 1991- 92,
midyear budget cuts reduced planned equipment purchases by over 50
percent as $ 370,258 of $ 675,500 in authorizations were reverted to the
State treasury.
According to the consultants, the greatest shortage of equipment i s i n
the School for the Blind ( ASB). Advances in computer technology have,
they note, provided devices such as voice- to- type u n i t s , which can
greatly enhance the employability of visually- impaired students and help
them become i ndependen t , product i ve c i t i zens . ASB a l so needs Bra i l l e and
Speak and NoteTaker devices.
Consultants found, however, that PDSD's Center for Laboratory Studies and
i t s l i b r a r y of 10,000 computer accessible books are commendable uses of
new technology. They believe the new Learning Resource Building on the
Tucson campus w i l l f a c i l i t a t e development of a similar center there i f
budget constraints do not c u r t a i l equipment purchases.
ASDB Construction Proq- ram
A major building program at ASDB's Tucson campus, which began with
replacement of the food service bui lding ( as recommended in our 1987
a u d i t ) , w i l l be completed in December 1992 w i t h d e l i v e r y of f i v e other
new structures. The construction cost of the project is expected to
exceed $ 15.5 m i l l i o n ; however, the new buildings were acquired under 20
year l ease/ pu rchase agreements , w i t h annua l paymen t s of over $ 1 .6
m i l l i o n . ' Thus, the t o t a l cost is expected to exceed $ 33 m i l l i o n over
20 years ( see Table 3, page 59). In addition to the new construction,
two large modular buildings were bought and moved to the Tucson campus
for s l i g h t l y over $ 1 m i l l i o n .
( 1 ) Lease/ purchase payments vary from year t o year w i t h changes i n i n t e r e s t r a t e s ,
insurance c o s t s , and the o t h e r v a r i a b l e c o s t s .
TABLE 3
ESTIMATED COST OF CONSTRUCTION AND LEASE/ PURCHASE PAYMENTS
ON SIX NEW AND TWO USED MODULAR BUILDINGS
AT ASDB'S TUCSON CAMPUS
( Unaud i t ed 1
New Buildinqs
Food Service
High School
Middle School
Elementary School
Learn i ng Resources
Center
Auditorium
Unallocated Archi-t
e c t u r a l , Improvement
and Other costs( c)
SUBTOTALS
Modular Buildings
TOTALS
Estimated
Estimated Cost to State
Estimated Annua l Over Life of
Cost of Lease/ Purchase Lease/ Purchase
Construction( a) Pavment Aareements
( a) May 1, 1992 estimate of f i n a l costs f o r buildings under construction.
( b ) Final cost f o r completed b u i l d i n g .
( c ) Includes fees and costs comnon t o more than one b u i l d i n g , such as water and sewer and
other s i t e improvements.
Source: Arizona Department of Administration and ASDB Associate
Superintendent for Business and Finance.
The new construction addresses a v a r i e t y o f problems. Our 1987 audit
confirmed ASDB reports that the food service building was i n serious
d i s r e p a i r , w i t h f a u l t y beams, plumbing, and e l e c t r i c a l and f i r e control
systems, and recommended correcting a number of faults immediately and
replacing the building as soon as possible. In addition to our audit
recommendations, ASDB closed i t s auditorium due to structural problems,
determined that i t s library did not comply with Federal regulations on
handicapped access, and i d e n t i f i e d other buildings that needed major
renovations or replacement. Consequently, the Legislature approved the
construction o f f i v e new structures.
ASDB's construction budgets did not include monies to furnish and equip
the f i v e new buildings. An estimated $ 1.5 m i l l i o n w i l l be needed for
additional furnishings and equipment for these buildings.(')
Administrators expect to request about $ 400,000 per year for four years
to provide the funding necessary for furniture and equipment.
( 1 ) Some f u r n i s h i n g s and equipment already owned by the School w i l l be used i n the f i v e
new bui 1 dings .
SUNSET FACTORS
In accordance with A. R. S. $ 41- 2954, the Legislature should consider the
following 12 factors i n determining whether the Arizona School for the
Deaf and the Blind should be continued or terminated.
1. Obiective and pumse in establish in^ ASDB
The o r i g i n a l intent i n establishing the Arizona School for the Deaf
and the Blind ( ASDB) was to provide educational opportunities f o r
sensory- impaired children between the ages of 6 and 21. The 1988
Session Laws, Chapter 237 provides a further statement of purpose i n
that the School shall
. . . promote and maintain an educational opportunity of
adequate scope and q u a l i t y for sensory impaired children in
t h i s state which w i l l lead to an adult l i f e of independence
and s e l f - s u f f i c i e n c y , a meaningful personal, family and
community l i f e , and a useful productive occupational l i f e .
2. The effectiveness with which ASDB has met its obiective and purpose
and the efficiencv with which the Asencv has o~ erated
In general, ASDB appears to be e f f e c t i v e in providing educational and
other services to sensory- impaired children. Both recent
accreditation reports and our consultants found that ASDB educational
programs were of a high c a l i b e r , u t i l i z i n g modern c u r r i c u l a and
teaching methods. ASDB's building program i s replacing obsolete
structures with modern f a c i l i t i e s s p e c i f i c a l ly designed for serving
the sensory impaired. ASDB has developed and operates successful
regional programs for both preschool and school- age children.
However, the School could improve i t s e f f i c i e n c y by streamlining i t s
management structure at a savings of over $ 500,000 annually ( see
Finding I , page 7). The School could help ensure i t i s e f f e c t i v e by
increasing i t s e f f o r t s to evaluate i t s graduates' success i n
postsecondary education programs and employment ( see Finding V i , page
51).
3. The extent to which ASDB has o~ eratedw ithin the ~ u b l i cin terest
ASDB has operated within the public interest through i t s provision of
services to sensory- impaired students. ASDB provides direct
educational and other services to over 1,000 preschool through high
school- aged pupils in the State. In addition, ASDB is the only
residential school for sensory- impaired children in Arizona.
Further, ASDB also provides a variety o f resource services to school
d i s t r i c t s and administers the cooperative p i l o t program in the
northern part o f the State.
However, the public interest has not been well served by ASDB's use
of nonappropriated school funds ( see Finding 1 1 , page 19). The ASDB
Board could strengthen the School's a b i l i t y to operate within the
public interest by exercising i t s authority over School operations
and finances more e f f e c t i v e l y ( see Finding I V , page 37).
4. The extent to which rules and requlations promulaated by ASDB are
consistent with the leaislative mandate
Whether ASDB has authority to promulgate rules is unclear. Because
i t i s - not s p e c i f i c a l l y exempt from the requirements of the
Administrative Procedures Act as are other educational bodies, some
ASDB policy development may be subject to requirements and procedures
for rule making. See Sunset Factor number nine for further
discussion and recommendation.
5. The extent to which ASDB has encouraaed input from the public before
atina its rules and requlations and the extent to which it has
informed the public as to its actions and their expected impact on the
public
Again, whether ASDB has authority to promulgate some rules is
unclear. See Sunset Factor number nine for discussion and
recwrnenda t i on.
6. The extent to which ASDB has been able to investiaate and resolve
complaints that are within its iurisdiction
ASDB's enabling legislation does not establish a formal complaint
review process. Public law 94- 142 and State statutes authorize ASDB
along with the Arizona Department of Education to conduct due process
hearings to resolve any disagreements regarding student evaluation
and placement.
7. The extent to which the Attorney General or any other a~ olicable
auencv of State aovernment has the authoritv to prosecute actions
under its enablina lea- islation
ASDB's enabling legislation does not establish such authority.
8. The extent to which ASDB has addressed deficiencies in its enablina
statutes which prevent it from fulfillina its statutorv mandate
As a result o f issues detailed in our 1987 ASDB audit and the report
of a Joint Legislative Committee formed to study ASDB, a number of
statutory changes were proposed and adopted into law in 1988. These
changes increased the ASDB Board from 5 to 7 voting members; amended
the evaluation and placement process to mandate parent and local
school d i s t r i c t participation; required the Superintendent to report
annually to the Board on the use of monies received as donat